CBAM Default Value Risk Screening Tool
Quick CBAM Supply Chain Default-Value Risk Assessment
Select the 7 key situations below to make an initial assessment of whether your current supply-chain data may lead to CBAM default-value treatment. This is only an early risk indicator, but it points to the real risk areas: CBAM is never just a carbon-emissions calculation. It is also about whether each trade role has the ability to solve the problem. In many situations, the trade roles involved simply do not have that ability.
Suitable for importer-side internal screening
The result is for early importer-side judgement only and does not replace formal verification, legal advice or an official compliance conclusion.
Risk Inputs
The higher the total score, the higher the default-value risk1. If you import steel and your supplier is itself a steel trader, and neither side can look through to the real production process and original material information (not so-called third-party certificates or verification statements), stop the score calculation here. The importer’s risk and uncertainty are substantial; at this point you are relying on luck, or you need a professional reassessment of supply chain risk.
Special review
2. If your supplier is a pure trading company rather than an actual production factory (although they will often claim to be the factory), all risk scores below need to be doubled.
Total score x 2
3. Is your company, as a European importer, importing less than 1,000 tonnes in total per year?
+20
4. Is the unit value per tonne of your purchased product low, and is the supplier’s margin also low?
+40
5. Does this supplier export less than 2,000 tonnes per year to Europe, or is the relevant factory’s annual output below 10,000 tonnes?
+40
6. Does the supply chain for the product you purchase involve more than three roles? For example, beyond “steel mill - steel processor - product supplier”, are there additional roles such as steel traders, material distributors or outsourced key processes?
+30
7. Does the key raw-material producer (for example, a steel mill or aluminium plant) have no export business to Europe?
+80