Do importer need to report on CBAM goods that are placed under the inward processing regime?
CBAM becomes due only for goods that are released for free circulation in the EU. Thus, in the case of CBAM goods that are placed under a custom suspensive regime in view of their future export or in view of their processing, there is no CBAM obligation.
Note, however, that if a CBAM good leaves the inward processing regime to be placed on the EU market, then there is a CBAM obligation. In this case, the bill of discharge should be uploaded as a supporting document when submitting the CBAM report.
A CBAM reporting obligation also arises in the specific case where a CBAM good that was placed under inward processing is processed into a product that itself is no longer a CBAM good, and this final good is finally released for free circulation in the EU (see Article 6 of the Implementing Regulation). In this specific case, the CBAM report would contain information on the quantities and embedded emissions of CBAM goods placed under inward processing (Article 6(f) and (g) of the CBAM Regulation), but not on the quantities and embedded emissions of the final goods released for free circulation, because in the example, these goods are not CBAM goods themselves (i.e. Article 6(a) and (b) do not apply).
Source: EC’s Questions and Answers on CBAM
CBAM Regulation
CBAM Regulation 2023_1773
CBAM Regulation 2023_956