ESG considerations are increasingly relevant in export controls, highlighted by the human rights implications of the EU's Dual-Use Regulation and the Supply Chain Act. For those engaged in foreign trade, it is crucial to understand how ESG factors intersect with trade compliance, as well as the associated challenges and requirements.
All goods that are imported into, exported from or in transit through a country must be declared to the customs administration. On the basis of various legal provisions, the regulations and conditions for the passage of goods are checked and randomly inspected: What exactly is the product, who is transporting it, who is ordering it, are there any intermediate products, are the necessary documents, permits and certificates available? Could the product be subject to an ‘ESG law’? Which ESG laws are applied to the customs declaration? What are the responsibilities?
Carbon Border Adjustment Mechanism
Important issues include reporting and certification requirements for certain imported goods, EU embargoes and other foreign trade restrictions, anti-dumping duties, increased compliance or governance requirements for customs, and ensuring sustainable supply chains. The Carbon Border Adjustment Mechanism (CBAM) requires companies in the EU that import aluminium, cement, electricity, fertilisers, iron, steel or hydrogen to report and offset the associated carbon emissions contained in the imports of these products from countries outside the EU. Starting from the transition period that began in October 2023, importers are required to fulfil a reporting obligation. This includes reporting the emissions per tonne of imported goods. The offsetting of emissions that results from the purchase of so-called CBAM certificates will begin after the end of the transition phase (from January 2026).
Two types of costs
CBAM imposes two types of costs on companies: for CBAM certificates, the price of which is based on the EU Emissions Trading Scheme (ETS), and for the collection and reporting of emissions-related data. As CBAM is an important lever in Europe's drive to become the first carbon neutral continent, affected businesses can start preparing now.
With our CBAM-Ready-Sprint, which has already been used by many companies, we prepare your organisation for the new regulations using the following approaches:
- Impact analysis
- Maintenance of master data by our pricing experts
- Support with reporting requirements through our digital solution
- CBAM concept.
- Communication with your suppliers
- Analysis of the CBAM environment
- Analysis of existing structures and data and their use for CBAM
- Technical design with responsibilities, IT support, change management, operational and organisational structure, escalation points
- Process design
- Data collection
- Digital solution for meeting reporting requirements according to CBAM (Carbon Pricing Reporter)
Further services
- ESG-Due Diligence: Assessment of deal risk from an ESG perspective, both buyer/seller and strategic post-deal structuring
- Tax Governance: Identification and presentation of ESG functions in the internal customs organisation, e.g. as part of internal reviews and support in implementing optimisation recommendations and in complying with country-specific record-keeping and declaration requirements
- Monitoring legal developments
- Fit for CBAM Sprint
How can we help you further?
Product identification
Based on the company's historical data, we can analyse whether the company's products fall under the CBAM regulation.
This analysis is based on the assumption that the customs tariff numbers of the imported goods have been accurately identified.
Additionally, we can assist you with product classification and process development, enabling your team to classify your products independently in the future.
Data collection for CBAM reporting
CBAM reporting requires companies to collect emissions data from suppliers and manufacturers. To facilitate this, it may be necessary to amend contract clauses to ensure that suppliers and manufacturers provide the required information for accurate reporting.
Through our local network companies outside the EU, we can facilitate the collection of data and assist in the adaptation of contractual clauses. To help businesses, we have developed the “Trade Data Hub”, a reporting solution that automates data collection and enables manufacturers and suppliers to provide the required information in a timely manner.
Trade Data Hub
The “Trade Data Hub” can help your company reduce CBAM-related costs by automating emissions data collection and CBAM reporting. As an additional service, our tool can be linked to the company's ERP system, enabling real-time monitoring of the company's imports and supply chain costs.
An add-on enables your company to identify the flows and actors whose costs need to be included in your supply chains, as well as future emissions-related costs. You can also utilise our “Global Rate Finder” tool to conduct a detailed analysis of CBAM costs related to your supply chains, helping you identify potential changes needed for optimisation.
Overview of CBAM
Find out everything you need to know about the carbon border adjustment mechanism (CBAM) in our one-pager. Read a brief summary of what needs to be reported, who and what is affected, why it is important to act now and how we can support you with our CBAM Sprint.
Only available in German.
Your contact
Patrick Kalski Director, PwC Germany
patrick.kalski@pwc.com +49 151 16155570
© 2017 - 2026 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.
