It’s a wrap! CBAM Roundtables at our PwC Liege, Antwerp and Brussels Campuses on the topic of ‘CBAM: Transitional period – Lessons learnt from the first reporting’.


The events were attended by our clients and companies in scope of CBAM, the industry’s federation members, the officials from the Belgian Customs Authority as well as the members from the National Competent Authority for CBAM in Belgium, the FPS Public Health. 

We thank all the participants for their valuable insights and sharing their experiences with CBAM compliance, testimonials and feedback on the CBM reporting and the active participation for suggestions for improvements.

Some of the key observations from our session included:

  • Most of the participants are struggling with their supply chains to ensure their suppliers are collaborative on sharing the actual carbon footprint of the imported products.
  • Overview and access to import data remains a key challenge for most companies.
  • Most of the participants submitted their CBAM report based on manual entries using the EU Commission’s Default Values for the GHG data.
  • Access to the CBAM Registry was, by far, the most popular issue faced by the reporters until the last minute. 

Some of the key takeaways for future reports and dealing with CBAM included:

  • Ensuing effective communication with the 3rd country suppliers to request for the mandatory CBAM data fields for CBAM reporting.
  • Need for automation in import data and GHG data consolidation.
  • Consolidating carbon footprint and supply chain traceability data from the CBAM exercise with other environmental regulations and due diligence reporting for effective data management and re-use.
  • Fitting CBAM in the imported goods’ procurement strategy. 
  • Ensuring traceability in the supply chain is a key concern and question mark for many companies.
  • Possible inclusion of more goods from 2026 is foreseen, so companies need to stay updated on the regulation’s constant evolutions.
  • The authorities are checking for unsubmitted reports and companies can expect to be notified if they failed to report for Q4 of 2023.
  • It is important to update the CBAM registry with company’s contact details (email address) to ensure the authorities can do effective correspondence with the reporters on the status and feedback of their report.

Besides these, we collected some valuable feedback and questions for the CBAM authorities from our clients. For more on this, stay tuned to our future posts!

Based on our collective findings from the session, we highly suggest companies in scope of EU CBAM to already start preparing for reporting based on actual GHG data with their suppliers and overseeing traceability and optimisation in their supply chains.

Our PwC Global Trade and Customs Advisors, CBAM experts and ESG & Sustainability data specialists are here to help should you have any questions on the CBAM challenge, and making CBAM a broader part of your Sustainability initiatives and compliance. Please reach out and we are happy to help!