Croatian importers face CBAM data gaps before 2027 certificate sales

Croatian importers face problems obtaining and verifying overseas suppliers’ production and emissions data ahead of the first Carbon Border Adjustment Mechanism (CBAM) certificates becoming available for purchase on 1 February 2027. Customs officials and industry specialists raised the issue at the Green Energy Fair in Zagreb, citing concerns about supply-chain readiness, not a new Croatian tax or a change to European rules.

Karlo Novosel, a department head at Croatia’s Customs Administration, warned that some companies were submitting applications for CBAM authorisation at the last moment. The requirement applies to importers within the regulatory scope, subject to relevant exemptions and transitional provisions. Novosel pointed to the first certificate sales as a key milestone for companies preparing their documentation.

Importers may underestimate how much production and emissions information they need from overseas manufacturers, said Marko Groš, who is associated with TÜV Nord Adriatic. Knowing a shipment’s quantity and customs classification does not necessarily provide the information needed to calculate its verified embedded emissions. The documentation burden remains even when importers know which products fall within CBAM.

Closing the data gap requires cooperation with the factory producing the material, as well as access to installation records, production processes, precursor data and relevant monitoring information. Importers cannot independently produce production evidence that their foreign suppliers have not collected.

Ana Jurjević, chief executive of Kariqa Solutions, identified communication between importers and manufacturers as a major obstacle, particularly for smaller businesses with limited compliance resources. Smaller exporters may face disproportionate administrative costs because they lack dedicated emissions-accounting and compliance teams.

The issue affects Croatian industrial buyers sourcing steel, aluminium, cement and other materials from neighbouring non-EU markets, including Serbia, Bosnia and Herzegovina, and Montenegro. Delays in obtaining emissions data could affect shipment documentation and contract negotiations, as well as the eventual choice between verified actual emissions and applicable defaults. Uncertainty over documentation can also create uncertainty over the final price paid for imported materials.

European buyers may centralise supplier data collection, set standard reporting formats or transfer some documentation obligations into contracts. The Zagreb discussions highlighted access to production evidence and emissions information as the operational problem facing importers and their overseas suppliers.

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