5 CBAM Reporting Errors Importers Make (and How to Fix Them)
After analysing thousands of CBAM submissions across EU member states, five errors appear consistently. Here is how to identify and fix each one.
Error 1: Incorrect CN Code Classification
The problem: Using wrong or outdated CN codes for CBAM-covered products. This is the most common error, affecting an estimated 30% of submissions.
Why it happens: CN codes are updated annually. Importers often use codes from previous years or confuse similar product categories.
How to fix it: Always verify CN codes against the current EU Combined Nomenclature. Pay special attention to:
- 8-digit vs 6-digit codes (CBAM uses 8-digit)
- Product subcategories (e.g., flat-rolled vs long products for steel)
- Annual updates released in October
CbamTrack automatically maps your products to the correct CN codes using its built-in CN code database, updated annually.
Error 2: Miscalculating Indirect Emissions
The problem: Forgetting to include indirect emissions or using incorrect indirect emission factors.
Why it happens: Indirect emissions are calculated separately from direct emissions, and many importers overlook them or apply the wrong factor.
How to fix it: Always calculate both direct and indirect emissions for every product. Use the indirect factors published in IR (EU) 2025/2621, which vary by country and product category.
Error 3: Missing Country of Origin Documentation
The problem: Not maintaining proper documentation for the country of origin of imported goods.
Why it happens: Emission factors vary by country of origin. Without proper documentation, auditors cannot verify that the correct factor was applied.
How to fix it: Maintain a centralised database linking each product import to its country of origin. Store certificates of origin and supplier declarations with your CBAM records.
Error 4: Using Outdated Default Emission Factors
The problem: Applying emission factors from previous years instead of the latest published values.
Why it happens: Default factors are updated annually. Importers often continue using factors from the previous year without realising they have changed.
How to fix it: Check for updated default factors at the beginning of each year. CbamTrack's emission factor database is updated automatically when new factors are published.
Error 5: Inconsistent Product Naming
The problem: Using different names for the same product across different quarters.
Why it happens: Multiple team members enter product data without standardised naming conventions.
How to fix it: Create a standardised product catalogue with consistent naming. Use the same product name in every quarterly report. CbamTrack enforces consistent naming with product name validation.
Prevention Checklist
- Use up-to-date CN codes for every product
- Calculate both direct and indirect emissions
- Document country of origin for all imports
- Verify emission factors annually
- Standardise product names across your catalogue
- Review each report before submission
- Maintain an audit trail of all data sources
- Use automated validation tools
FAQ
How do I know if my CN code is correct? Cross-reference with the EU TARIC database and check for annual updates. CbamTrack's CN code search includes automatic validation.
Can I correct errors after submission? Yes, within two months of the deadline. Submit an amended report through the CBAM Transitional Registry.
Are there penalties for reporting errors? Penalties apply for incorrect data if discovered during an audit. Correcting errors voluntarily before an audit typically avoids penalties.
Catch Errors Before They Cost You
Manual CBAM reporting is prone to the five errors above. CbamTrack's validation engine automatically checks for incorrect codes, missing data, inconsistent naming, and anomalous values before you submit.
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