An importer-level exemption from the Carbon Border Adjustment Mechanism (CBAM) could reduce the number of businesses directly covered while leaving a large share of supplier relationships exposed to requests for emissions information, according to research by ERCST.
The study, published on 30 September, examined 63,405 import shipments, with the sample concentrated in automotive, machinery and equipment supply chains.
Importer threshold removes fewer emissions from coverage
Under a cumulative 50-tonne importer threshold, the modelling found that 54% of importers would be excluded from CBAM while 99.5% of emissions would remain covered.
At the same time, more than 90% of supplier relationships in the sample would remain within the scope of emissions-related information requirements.
A different model combining the 50-tonne importer threshold with a one-tonne threshold for each importer–supplier relationship produced a larger reduction in the number of relationships covered. It exempted 74% of supplier relationships while retaining 98.5% of emissions.
Supplier data requirements remain significant
The results indicate that reducing the number of importers subject to CBAM does not necessarily produce a proportional reduction in the administrative burden across their supply chains.
The study’s figures are modelling results, rather than adopted CBAM rules or estimates covering all EU imports. ACEA co-funded the research.
For policymakers, the findings highlight the challenge of reducing compliance requirements while maintaining emissions coverage and avoiding incentives to fragment shipments.
