Roles in CBAM Reporting: Why Operator and Importer (RBS) Definitions are Critical?

The Importance of Operator and Importer Roles in CBAM Reporting: Why Proper Identification is Essential

Border Carbon Regulatory Mechanism (CBAM) reporting requires clearly defining the roles and responsibilities of different actors. To facilitate this process, CimpactPro software allows you to define key roles such as European Union (EU) importer (Reporting Declarant or RBS - Reporting Declarant/Buyer Representative) and third country producer (Operator). But why are these roles so important, how are their information entered into the system and how do these definitions affect the audit process?

Defining Roles: Who is Who?

When you first log in to CimpactPro, you need to define the key players in the reporting process:

• Manufacturer (Operator): The company that manufactures and exports the product in a country outside the EU.
• EU Importer (RBS): The party that imports the product into the EU and is responsible for CBAM reporting (this can be the importer itself or an authorized representative).
• Sub-Suppliers: If necessary, other sub-suppliers involved in the production process can be added to the system.

These definitions only need to be made once; the system automatically remembers this information for subsequent reporting. However, the area where this information is entered is highly confidential and should only be managed by company officials and should not be shared with third parties.

Not Just Registration, but Liability Separation

Correctly identifying the different roles is not just a data entry process; it is also a disaggregation of obligations. CBAM calculations and potential taxation are based on information such as who owns the product, who manufactured it and who imported it.

• Calculation Differences: These roles need to be clear so that the system can accurately distinguish between emissions from on-site activities and emissions from goods purchased from outside (suppliers). Taxation and the emission factors to be used may vary according to this distinction.

EORI Number and Tax ID: Does Missing Information Impede the Process?

Information such as the EORI (Economic Operator Registration and Identification) number or tax ID of the EU importer is also requested during reporting. Ideally, this information should be entered directly by the importer (your European customer). But what happens if the manufacturer does not have this information?