CBAM Scorecard of Complex Products: Why Component Ratios Are So Critical

CBAM Complex Product Reporting: The Importance of Component Ratios

In CBAM reporting, the accuracy of the calculation is directly dependent on the component ratios and functional unit information entered, especially for so-called "complex products", which consist of multiple components. The percentage distribution of raw materials and alloys used in production serves as a critical multiplier in the final emission calculation. So why is it so important to enter this information in full and how does missing information affect the audit process?

Why Complete All Component Information?

In complex products, component ratios and functional unit information form the basis of the calculation.

Risk of Incorrect Calculation: Entering these figures incorrectly will cause the entire calculation to be inaccurate in a chain.
Correct Data Set: The user must accurately enter the exact amount of raw material used, from how many suppliers and how much, and what percentage of this raw material is used in their final product. The accuracy of the calculation is only possible with the accuracy of this data.

Will the Emission Calculation Deviate if Alloy Information is Missing?

Yes, especially if the component reports of mixtures such as alloys are incomplete, the emission calculation is expected to show some deviation.

Inadequacy of General Factors: Some generic emission factors used in the calculations may only be "acceptable" average figures for specific blends, but may deviate somewhat from the actual emission value of the product.
post-2026 Prospect: Starting in 2026, the European Union plans to require companies to use specific emission factors directly from their suppliers instead of these general factors. Once this real data from suppliers is used, the existing risk of deviation will be completely eliminated.

Critical Role in the Verification Process

This percentage information of complex products plays a vital role in the CBAM verification process.

Risk of Miscalculation: Entering percentages incorrectly runs the risk of miscalculating the direct emission burden, which is one of the first issues to be recognized in an audit.
Auditor Request: During the verification phase, the auditor may request detailed information about the proportions of raw materials used in your product. In order to prevent this error and possible inquiries, it is essential to enter the data correctly from the beginning.

Does Missing Ingredient Information Lead to Audit Rejection?

So, if this information is missing, will your report be rejected directly from the audit? No, the process usually does not work this way.

Non-Conformity and Correction: It will not lead to an audit rejection; instead, the auditor will record the omission as a "non-conformity" and request that you correct the information.
Trade Secret Exception: If the missing information is a "trade secret" that you do not wish to disclose, the nonconformity can be removed if you reasonably disclose it to the auditor.

However, the ideal scenario for the process to run smoothly and quickly is for all component information to be transparently and completely entered into the system from the outset.