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CBAM Reporting Software: What SA Exporters Need

Selecting the right CBAM reporting software is critical for SA exporters. This guide explains what data you need to collect, what the software must produce, and how to avoid common pitfalls.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

The CBAM Data Challenge

CBAM compliance is fundamentally a data problem. The EU CBAM Implementing Regulation (Commission Implementing Regulation (EU) 2023/1773) specifies in detail what data must be collected, how it must be calculated, and in what format it must be reported. SA exporters who cannot produce this data in the required format will have their EU buyers default to EU default values — with significant cost consequences.

What Data CBAM Requires

The EU CBAM regulation requires the following data for each covered product:

Direct Embedded Emissions (Scope 1):

  • Fuel combustion emissions from production processes
  • Process emissions (e.g., CO₂ from limestone calcination in cement production)
  • Emissions from on-site electricity generation

Indirect Embedded Emissions (Scope 2):

  • Emissions from purchased electricity, heat, and cooling
  • Calculated using either the actual emission factor of the electricity source or the default factor for the country of origin

Production Parameters:

  • Production volume (tonnes of covered product)
  • Specific embedded emissions (tCO₂/tonne of product)
  • Attribution of emissions to specific product types where multiple products are produced

Carbon Price Data:

  • Carbon price paid in the country of origin (for the SA carbon tax credit)
  • Evidence of actual payment (tax receipts, compliance certificates)

What Good CBAM Reporting Software Does

Effective CBAM reporting software for SA exporters should:

  1. Collect production and energy data from existing operational systems (ERP, energy management, fuel consumption records)
  2. Calculate embedded emissions using the methodology specified in the EU CBAM Implementing Regulation
  3. Apply the SA carbon tax credit calculation correctly
  4. Generate the required data outputs in a format compatible with the EU CBAM Registry
  5. Maintain an audit trail for third-party verification
  6. Track changes over time to demonstrate emissions reduction progress

The Digital Product Passport Registry Approach

Rather than implementing standalone CBAM reporting software, SA exporters can use the Digital Product Passport Registry as their CBAM compliance platform. The Registry:

  • Guides you through the data collection process
  • Calculates your embedded carbon using EU-compliant methodology
  • Connects you with accredited third-party verifiers
  • Produces a verified carbon report in the format your EU buyers need
  • Maintains your compliance record for the required 5-year retention period

For a complete CBAM compliance registration pathway, visit the Digital Product Passport Registry.

Frequently Asked Questions

What data does CBAM reporting software need to collect?
CBAM reporting software must collect: (1) production volume data (tonnes produced per period), (2) direct emissions data (Scope 1 — fuel combustion, process emissions), (3) indirect emissions data (Scope 2 — purchased electricity, heat, cooling), (4) production process parameters (as required by the EU CBAM Implementing Regulation), and (5) carbon price data from the country of origin (for the SA carbon tax credit calculation). The software must produce outputs in the format required by the EU CBAM Registry.
Does CBAM reporting software need to be EU-approved?
There is no formal EU approval process for CBAM reporting software. However, the data outputs must conform to the format and methodology requirements of the EU CBAM Implementing Regulation (Commission Implementing Regulation (EU) 2023/1773). The EU CBAM Registry has specific data submission formats that your reporting software must be able to produce.
Can SA exporters use the EU CBAM Registry directly?
The EU CBAM Registry is used by EU importers (authorised CBAM declarants), not by SA exporters directly. However, SA exporters must provide their embedded carbon data to their EU buyers in a format that the EU buyer can enter into the CBAM Registry. The Digital Product Passport Registry provides SA exporters with a verified carbon report in the correct format for their EU buyers to use.
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