CBAM obligations apply only to goods released for free circulation in the EU. Therefore, if CBAM goods are placed under a customs suspensive regime for future export or processing, there is no immediate CBAM reporting obligation.
However, it’s essential to note that if a CBAM good exits the inward processing regime to enter the EU market, CBAM obligations then apply.
Furthermore, there’s a specific scenario where a CBAM reporting obligation arises: when a CBAM good placed under inward processing is processed into a product that is no longer classified as a CBAM good, and this final product is released for free circulation in the EU (as per Article 6 of the Implementing Regulation).
In this specific case, the CBAM report would include information on the quantities and embedded emissions of CBAM goods placed under inward processing. Still, it would not cover the quantities and embedded emissions of the final goods released for free circulation because they are not classified as CBAM goods themselves.
And remember, Dubrink’s CBAM platform offers comprehensive tools to streamline CBAM compliance effortlessly! If you want to know if your goods are CBAM goods, please use the Free CBAM Identifier.