We make your CBAM data so clean
your external auditor signs off in minutes, not weeks.
Iron & steel importers face two overlapping obligations with different data requirements. PassportLab's unified intake form captures the structured supplier data both frameworks need — eliminating duplicate questionnaires and giving your compliance team a single, validated dataset ready for external review.
One intake form. Two regulatory outputs.
ESPR and CBAM have different system boundaries and methodologies — ESPR follows product category lifecycle rules while CBAM measures emissions at the factory fence line. PassportLab captures the data required for both in a single structured supplier intake, so your team avoids running two separate questionnaire campaigns. Each output is correctly scoped for its regulator.
- Steel grade, heat number, production route
- Recycled content, hazardous substances
- Embedded CO₂ (tCO₂e/tonne)
- Mill certificate reference
- Embedded emissions per tonne (same field)
- Production country, facility name
- CN code (8-digit), CBAM authorisation
- Carbon price paid in origin country
- 10 CBAM readiness checks (BC1–BC10)
- Live ETS price → certificate exposure
- CBAMAnnualDeclaration XML per Implementing Regulation (EU) 2024/3210
- Cryptographically signed DPP as audit proof
Embedded Emissions Pre-Fill
Every DPP you create in PassportLab captures cbamEmbeddedEmissions (tCO₂e/tonne), cbamMethodology, cbamSystemBoundary, and cbamProductionCountry as structured, validated fields — not free-text. When your supplier submits via the PassportLab supplier portal, those fields populate your CBAM XML export with no manual transcription between systems.
PassportLab validates all 10 CBAM fields on every DPP scan for iron, steel, and aluminium products: declarant number (EU + 11 alphanumeric), importer EORI format, embedded emissions value (> 0 tCO₂e/tonne), production route (BF-BOF / EAF / DRI-EAF), production facility name, production country (ISO-2), CN code (exactly 8 digits), heat/batch number, carbon price paid (amount and currency), and scope set to direct_only per CBAM Annex III.
CBAM Certificate Exposure Calculator
Before you file, know exactly what you owe. PassportLab pulls the live ETS carbon price from Ember Climate (refreshed every 24 hours), multiplies it by your embedded emissions per tonne and your annual shipment tonnage, then deducts any carbon price already paid in the origin country.
The calculator also shows the free-allocation phase-out schedule: 97.5% offset in 2026, 95% in 2027, declining to 0% by 2034 — so your finance team can model CBAM liability across the full transition period, not just this year.
Example figures. Live ETS price is fetched at calculation time and cached for 24 hours.
Annual Declaration XML Export
When all 10 checks pass, PassportLab generates a CBAMAnnualDeclaration XML file structured per Implementing Regulation (EU) 2024/3210. The ZIP archive includes the signed DPP JSON-LD as a "DPPReference" — giving customs auditors a cryptographically verifiable audit trail linked directly to the declaration.
Upload the XML directly to the EU CBAM Trader Portal. No manual transcription. No CSV pivot tables. If the underlying DPP data changes, regenerate in one click.
<CBAMAnnualDeclaration> <reportingYear>2027</reportingYear> <declarantNumber>EU123456789</declarantNumber> <goods> <cnCode>72081010</cnCode> <embeddedEmissions>1.82</embeddedEmissions> <DPPReference> https://passportlab.io/dpp/DPP-… </DPPReference> </goods> </CBAMAnnualDeclaration>
Why importers choose PassportLab before the deadline
CBAM Data Mapping Assessment
A PassportLab technical specialist maps your existing supplier and ERP data fields to the CBAM declaration schema, configures your PassportLab workspace for accurate XML export, and identifies gaps in your data capture process. This is a technical data configuration service — not a regulatory compliance certification or legal audit under Regulation (EU) 2023/956.
- 10-field CBAM data gap analysis against your existing product and ERP data
- Supplier field mapping to CBAMAnnualDeclaration schema
- PassportLab workspace configuration for your product categories
- Data capture gap report with field-level configuration guide
- 30-minute technical debrief call
- PassportLab setup included — import your first DPP during the call
CBAM questions, answered
Who is subject to CBAM for iron and steel?
Any EU importer of iron and steel goods covered by CN codes in Annex I of Regulation (EU) 2023/956 must hold a CBAM authorisation and file an annual declaration by 30 September each year, starting 2027. This includes hot-rolled coils, sections, wire rod, tubes, and a wide range of semi-finished and finished steel products.
What data do I need to file a CBAM declaration?
You need: embedded greenhouse gas emissions per tonne (direct + indirect for some goods), production country, production facility name and coordinates, CN code (8-digit), the carbon price paid in the country of origin (if any), and the reporting period tonnage. PassportLab stores all of these as structured DPP fields when your supplier submits their data.
How does PassportLab connect ESPR and CBAM data?
ESPR and CBAM have different system boundaries — ESPR applies product category lifecycle rules while CBAM measures emissions at the factory fence line per EU ETS methodology. However, both draw on many of the same underlying supplier data points. PassportLab captures all required fields in a single structured intake, eliminating duplicate supplier questionnaires. The CBAM XML export reads from those validated DPP fields, reducing manual transcription and inconsistency between systems. Your external auditor or customs advisor reviews the final declaration before submission.
Is the XML PassportLab generates accepted by the EU CBAM Trader Portal?
The export is structured per Implementing Regulation (EU) 2024/3210, which lays down the rules for the CBAM registry including the declaration schema. The archive also includes the signed DPP as a DPPReference element, providing an auditable link back to the underlying product data. We recommend validating the XML against the official XSD before upload.
What is the ETS price used in the calculator?
PassportLab fetches the EU ETS carbon price from the Ember Climate API and caches it for 24 hours. The CBAM certificate price is set by the EU Commission weekly based on the average ETS auction price — the calculator uses the spot price as a proxy and will be updated to use the official weekly CBAM price once the Trader Portal makes it available via API.
Can I use PassportLab only for CBAM, without ESPR?
Yes. You can create a DPP solely to generate the CBAM XML export — the platform does not require you to use every feature. That said, since the EU mandates both for iron and steel from 2027, most importers find it more efficient to complete both from a single workflow rather than revisiting the data twice.
Stop running two separate supplier questionnaires for CBAM and ESPR.
PassportLab includes a built-in CBAM XML export. Capture your supplier data once — structured, validated, and audit-ready. Your compliance team spends minutes reviewing, not weeks collecting.
Draft standards notice: prEN 18222 and prEN 18246 are pre-normative CEN draft standards subject to change before publication. EU 2024/1781 (ESPR) delegated acts and Annex I requirements are still being developed. CBAM Reg. 2023/956 reporting obligations continue to evolve under Commission guidance. Results reflect the latest available drafts and do not constitute legal advice.