CBAM Disclosure

1. What this service is

The CBAM tools operated at /cbam implement the European Union’s Carbon Border Adjustment Mechanism per Regulation (EU) 2023/956 and the December 2025 implementing-acts package. The free tools (scope checker, calculator, decision tree, quarterly-report checker) are offered without account registration and without rate-limit charges within the published per-IP limits. Paid deliverables are the one-time CBAM cost report PDF and the recurring CBAM Pro subscription (bulk CSV, ICR client roster, watchlists, declaration draft generator, REST API).

2. What this service is NOT

• It is not legal, tax, or customs advice and creates no advisory or fiduciary relationship between you and us.
• We are not an authorised CBAM declarant on your behalf, not your Indirect Customs Representative, and not your National Competent Authority. We do not interact with the EU CBAM Registry, the Authorisation Management Module, or any Member-State authority on your behalf.
• We are not an accredited CBAM verifier under Delegated Regulation (EU) 2025/2551. When the calculator accepts a “verified” intensity input, the value is taken as-supplied by you; we do not perform verification.
• The calculator does not file your CBAM declaration or purchase certificates. The CBAM Pro “declaration draft generator” produces a transcription PDF only — final filing must be submitted via your national CBAM portal.
• We do not provide guidance on whether you qualify as an “authorised CBAM declarant” in any specific jurisdiction; the decision-tree widget is a generalised mirror of the EU’s public infographic, not an official determination.

3. Calculation methodology + sources

Every numeric value in our tools traces to an official EU source. We do not paraphrase, interpolate, or substitute training-data values for any rate, intensity, benchmark, or price. Where the EU has not published data for a specific combination, the calculator returns “Outside scope of automated calculation — contact your NCA” rather than guessing.

• Scope (CN-code coverage). Annex I of Regulation (EU) 2023/956. Six sectors: cement, iron & steel, aluminium, fertilisers, electricity, hydrogen.
• Default emissions values.The Commission’s “DVs as adopted” Excel (per Implementing Regulation (EU) 2025/2621), refreshed weekly via hash check + on-publication reseed.
• Calculation methodology (direct vs indirect). Implementing Regulation (EU) 2025/2547. Indirect emissions are included in the surrender obligation for cement, fertilisers, electricity, and hydrogen; for iron & steel and aluminium they are reported but not surrendered.
• Free-allocation deduction. Implementing Regulation (EU) 2025/2620 + the Commission’s quarterly CBAM Benchmarks Excel.
• Origin-country carbon-price deduction. Article 9 of Regulation (EU) 2023/956. Deduction is applied to the value you enter in the “origin carbon price already paid” field; we do not maintain a real-time carbon-price feed for jurisdictions outside the EU.
• Certificate price. Implementing Regulation (EU) 2025/2548 — published by the Commission as a derived weighted average of EU-ETS auction clearing prices, quarterly during 2026 and weekly from 2027 onwards. We scrape the EU’s certificate-price page daily; the publication day per quarter / per week is the only one where the value changes.
• National Competent Authority lookup.The Commission’s consolidated NCA list (PDF, last refresh 5 January 2026), reseeded annually.
• Penalty exposure (transitional period). Article 28 of Regulation (EU) 2023/956 (€10–50/t indexed) applied to user-supplied unreported tonnage in the quarterly-report checker. We do not estimate penalties for the definitive period (3–5× certificate price) — that assessment is for your NCA.

Every calculator output, every paid PDF, and every API response carries inline source URLs and the regulation Article reference for each value used. You can verify any number we display in one click.

4. Verified · Default · Estimated labelling

The calculator distinguishes three sources for any emission intensity:

• Verified— a value you supplied via the optional “Verified direct/indirect intensity” input. Our tools take the value as-supplied; verification under (EU) 2025/2551 requires an accredited verifier (which we are not). Use of a “verified” value here does not constitute verification.
• Default— the EU’s published default for the country × CN-code × production-route combination, with the statutory mark-up applied per (EU) 2025/2547 for the appropriate import year (2026, 2027, 2028+).
• Estimated — a chapter-level fallback (when the EU publishes a CN-chapter heading without an 8-digit-specific entry) or sector default. Surfaces with a visible caveat in the calculator output.

Every PDF report records which method was used per row.

5. Data freshness + automatic freezes

Each upstream source is re-fetched on a published cadence. The last successful refresh + last detected change for every source is shown live on /cbam and on the operator dashboard. We do not silently mask refresh failures.

• Certificate price — daily check; quarterly publishes during 2026, weekly from 2027.
• Default values + benchmarks + scope + NCA — weekly hash check; full reseed on detected change.
• Operational PDFs + main pages — weekly hash check; alerts queue a manual source-audit task.

If the EU publishes a new data file and our automated re-parse fails (e.g. unexpected schema change), paid PDF generation for the affected sectors freezes automatically until our operator re-audits the source. The free calculator continues to serve the last known-good values with a visible “as-of” badge so you are never silently shown stale numbers.

6. Scope (what the tools cover)

We cover the six CBAM sectors per Annex I of Regulation (EU) 2023/956: cement, iron & steel, aluminium, fertilisers, electricity, hydrogen. Out-of-scope CN codes return “outside scope” with a link to your NCA — never a guessed answer. We do not cover:

• Embedded emissions in finished or downstream products that are not themselves listed in Annex I.
• Non-EU emissions trading schemes’ current spot prices (we accept your input for the origin-country deduction; we do not maintain a UK ETS / China national / Korea KETS feed).
• Data Reconciliation for Monitoring & Control (DRMC) and related forthcoming EU systems still being defined.
• Authorisation Management Module direct integration (the EU portal has no public API; CBAM Pro produces a transcription draft).

7. No warranty & limitation of liability

The CBAM tools are provided “as is” and “as available”, without any warranty of any kind, whether express or implied, including without limitation any warranty of merchantability, fitness for a particular purpose, accuracy, completeness, suitability for filing with any authority, or non-infringement. We do not warrant that calculator output, PDF reports, declaration drafts, or API responses will satisfy any legal or regulatory obligation imposed on you, your client, or any other party.

To the maximum extent permitted by applicable law, our aggregate liability for any claim arising out of or relating to your use of the CBAM tools is capped at the lesser of:

• the amount you have paid us for the specific output that gives rise to the claim — for one-time pay-as-you-go PDF reports, the purchase price of that report (per the tier published on /pricing); for the CBAM PRO subscription, the most recent billing-period subscription fee; or
• €100.

We expressly exclude liability for indirect, incidental, special, consequential, exemplary, or punitive damages, including without limitation: shipment delays, customs holds, EU CBAM penalties (whether imposed under Article 28 of Regulation (EU) 2023/956 or otherwise), certificate-price movement losses, lost profits, lost contracts, lost data, or reputational harm. This limitation applies in addition to, and is subject to, the limitation of liability and disclaimers in our general Terms of Service.

8. Indemnity

You agree to indemnify, defend, and hold us harmless from any third-party claim arising from your reliance on, or use of, our CBAM tools — including without limitation a claim by your customer, employer, or counterparty that a CBAM cost quote, declaration, or report you supplied to them was inaccurate, incomplete, or untimely. This indemnity does not extend to claims caused by our gross negligence or wilful misconduct.

9. Acceptance + version

The current version of this disclosure is 2026-04-30. Use of the free calculator and scope checker is governed by this disclosure plus our Terms of Service and Privacy Policy. Purchase of a paid CBAM cost report PDF requires explicit acceptance via a checkbox on the checkout flow; the per-purchase consent (timestamp + version) is recorded against your purchase row and printed in the PDF footer for audit traceability.

A CBAM Pro subscription requires acceptance via a one-time modal on first dashboard visit after signup; the consent is recorded against your subscription row. When this disclosure is materially updated, we bump the version, and the modal re-prompts you on next dashboard load. Paid CBAM Pro features (bulk CSV, watchlists, declaration drafts, API) grey out until you accept the updated version. The general invoice and customs-clearance features of the Service are unaffected by a CBAM disclosure version bump.

10. Defects + corrections process

If you believe a calculator output, PDF report, declaration draft, or API response is contradicted by the official EU source we cite, please contact us at support@customs-invoice.com with the report ID (or the API request you ran) and the EU document URL + section that you believe contradicts our output. We will re-audit, and where confirmed:

• Re-issue the corrected PDF report at no additional charge; and
• Refund the original purchase regardless of the 30-day money-back window in our Refund Policy.

We respond to defect reports within five business days.

11. Contact your National Competent Authority

For any binding determination — whether you are an authorised CBAM declarant, whether a specific shipment qualifies for exemption, whether a verified emissions value will be accepted on filing, or whether a missed transitional report can be retrofitted — contact your NCA. The scope checker on /cbam surfaces your NCA’s name + URL based on your country of establishment. The full Commission-published NCA list is at this PDF (last refresh 5 January 2026).

12. Changes to this disclosure

We will update this page when material changes occur to data sources, methodology, freshness guarantees, scope, paid-tool gating, or our liability position. The version field at the top of this page reflects the most recent revision. Continued use of the CBAM tools after publication of an updated disclosure constitutes acceptance of the changes for the free tools; for paid tools, see Section 9.