What is the relevant time period for calculating embedded emissions? Can data from previous years be used?
The default reporting period, i.e. the reference period for operators for determining embedded emissions, is a calendar year. However, it may be justified to use other periods (such as a fiscal year) provided that they ensure similar coverage and cover at least 3 months. More details can be found in the Guidance documents under Section 4.3.4 (for EU-importers)/ Section 4.3.3 (for non-EU installations).
If operators monitor their emissions on the basis of a calendar year, then they need to start monitoring emissions according to the CBAM methodology already in 2024 so that all required data are available for goods produced in 2024 and imported in 2025.
For the CBAM report due in the first quarter of the year, the data of the previous year should be used. In cases where such data are not yet available until the end of January/February, data of the year before could be used.
Concerning stock items, see the question “How to deal with stock items for which there is no emission data available?”.
Source: EC’s Questions and Answers on CBAM