02 // The Methodology
From readiness scan to lodged declaration — one mandate.
A twelve-week sequence from supply-chain readiness to a CBAM declaration lodged via the EU Registry. No phase begins without written scope confirmation. No deliverable leaves without the regulatory anchor cited in working papers.
Reg (EU) 2023/956 · IR (EU) 2025/2620 · IR (EU) 2025/2621 · Reg (EU) 2025/2083
Week 01
Exposure mapping
Sector flows mapped against the CBAM scope register. Data maturity audited consignment by consignment. Liability projected through the 2026 → 2028 mark-up ramp against the live ETS reference.
Week 04
Plant onboarding
Supplier engagement structured to Annex IV calculation methods. Plant-level activity, fuel and process-emission data ingested. Chain-of-custody governance stood up to the verifier standard before the first declaration cycle.
Week 12
Definitive filing
Verified evidence pack assembled. CBAM declaration prepared, reconciled to the import ledger, and lodged via the EU CBAM Registry. Position holds under Article 19 review and Commission audit by construction.
The Cycle
Annual declaration. Quarterly certificate cover.
First definitive declaration deadline per Reg (EU) 2025/2083 (Omnibus). Covers 2026 imports. Subsequent cycles annual.
Per Art 22 of Reg (EU) 2023/956 (as amended). Declarants must hold CBAM certificates equal to at least 80 % of estimated embedded emissions at every quarter end.
Final surrender at annual declaration. Excess certificates re-purchasable per Art 23 for next-cycle use.
Failure to declare or surrender triggers penalties scaled to the EU ETS excess-emissions penalty, plus interest. Repeat or severe infringements compound.
Engagement
Begin the twelve-week mandate.
Engagement opens with a written readiness scan. No phase advances without scope confirmation. Mandate closes on the lodged declaration.