Scope and product codes
A CBAM assessment often starts with the product code, origin, volumes, and import setup. The first question is usually whether the goods are within scope at all and how the actual structure works.
We assist actors importing or handling emissions-intensive goods such as iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen. The advice focuses on whether goods are within scope, how responsibility should be allocated across the import chain, and how reporting, emissions data, and certificate-related questions should be structured.
A CBAM assessment often starts with the product code, origin, volumes, and import setup. The first question is usually whether the goods are within scope at all and how the actual structure works.
It often needs to be clarified who actually carries the CBAM responsibility: the importer, a direct customs representative, or an indirect customs representative with CBAM responsibility.
Questions around supplier data, actual or standard values, verification, registry flows, and certificates often need early legal and operational structure.
Advisory scope
Review of whether goods, CN codes, origin, import patterns, and volumes raise CBAM questions and which actors in the chain should be analyzed more closely.
Legal analysis of direct and indirect customs representation, including when CBAM responsibility remains with the importer and when the structure should be arranged differently.
Support on application-related questions, EORI linkage, organizational prerequisites, and the type of material that may need to be prepared for the registration and approval process.
Review of how supplier records, actual emissions values, standard values, verification, and information flows affect the legal risk picture.
Support on responsibility for reporting in the CBAM registry, handling discrepancies against customs data, and how internal responsibility should be documented.
High-level analysis of how certificate obligations, cost allocation, and information requirements may need to be reflected in contracts and internal processes.
Approach
Most matters start with several functions already involved: procurement, customs, sustainability, finance, and commercial teams. We therefore tend to begin with the responsibility chain and the practical data flow, not just the legal text.
We review goods, product codes, volumes, origin, EORI details, customs setup, and which actors actually operate in the import chain.
We identify the legal and practical issues that need to be clarified around declarant status, customs representatives, supplier data, reporting, verification, and certificates.
You receive a clearer basis for the next step: internal allocation of responsibility, contractual measures, application preparation, supplier dialogue, or continued legal support.
When advice often matters
When you need to assess whether specific goods or import flows are within CBAM at all.
When responsibility must be allocated between the importer and a customs representative, or when several group companies are involved.
When supplier emissions data, verification, or registry flows need to be translated into clear internal requirements.
When reporting, certificates, or cost allocation should be reflected in contracts, instructions, or compliance processes.
Common questions
No. The assessment depends, among other things, on whether the goods are covered, how the import is organized, and what volumes are involved. In the Swedish EPA's current guidance for the definitive period, a 50-ton annual threshold is one of the central reference points for key CBAM obligations, but the actual application should be assessed against current law and the specific setup.
In some structures, yes. The Swedish EPA's guidance distinguishes between direct and indirect customs representation, and responsibility is affected by the role chosen and how the setup has been documented. That should be reviewed carefully before the import chain is fixed.
Supplier and emissions data often need to be structured early, particularly if you want to work with actual values. Depending on the setup, standard values may also be relevant. The legal question is often how data responsibility, verification, and documentation should be allocated and secured.
Yes. The advisory work can begin with an assessment of whether the goods, volumes, and responsibility chain point toward your own declarant status or a different structure. The actual approval, however, is decided by the competent authority.