Croatian importers face gaps in obtaining and verifying overseas suppliers’ production and emissions data ahead of the first Carbon Border Adjustment Mechanism (CBAM) certificates becoming available for purchase on 1 February 2027. Customs officials and industry specialists raised the issue at the Green Energy Fair in Zagreb, highlighting concerns about supply-chain readiness, not a new Croatian tax or a change to European rules.
Karlo Novosel, a department head at Croatia’s Customs Administration, warned that some companies were submitting CBAM authorisation applications at the last moment. The authorisation requirement applies to importers within the regulatory scope, subject to relevant exemptions and transitional provisions. He pointed to the first certificate sales as a key milestone for companies preparing their documentation.
Importers may underestimate how much production and emissions information they need from overseas manufacturers, Marko Groš, associated with TÜV Nord Adriatic, said. Knowing a shipment’s quantity and customs classification does not necessarily provide the information needed to calculate its verified embedded emissions. The documentation burden remains even when an importer knows which products fall within CBAM.
Closing the data gap requires cooperation with the factory producing the material and access to installation records, production processes, precursor data and relevant monitoring information. Importers cannot independently produce evidence about production that their foreign suppliers have not collected.
Ana Jurjević, chief executive of Kariqa Solutions, identified communication between importers and manufacturers as a major obstacle, particularly for smaller businesses with limited compliance resources. Smaller exporters may also face disproportionate administrative costs because they lack dedicated emissions-accounting and compliance teams.
The issue affects Croatian industrial buyers sourcing steel, aluminium, cement and other materials from neighbouring non-EU markets, including Serbia, Bosnia and Herzegovina, and Montenegro. Delays in obtaining emissions data could affect shipment documentation and contract negotiations, as well as the eventual choice between verified actual emissions and applicable defaults. Documentation uncertainty can also make the final price paid for imported materials uncertain.
European buyers may centralise supplier data collection, set standard reporting formats or transfer some documentation obligations into contracts. Such measures could shape how buyers manage supplier information, while the underlying operational problem remains access to production evidence and emissions data from overseas manufacturers.
