Question 1

Why does CBAM hit German importers harder than most?

Accepted Answer

Germany is the EU’s largest manufacturing economy and its largest importer of CBAM-covered goods (iron and steel, aluminium, cement, fertilisers and hydrogen) drawn from many non-EU suppliers at once. A German declarant is rarely managing a single sector or a single origin; it is coordinating embedded-emissions evidence across several goods categories and dozens of installations into one declaration. The volume and the breadth of the supplier base — not any one calculation — is what makes the obligation heavy.

Question 2

Who is the competent authority for CBAM in Germany, and does Carbon Mandate file for me?

Accepted Answer

Germany’s national competent authority for CBAM is the German Emissions Trading Authority (Deutsche Emissionshandelsstelle, the DEHSt) within the Umweltbundesamt, which administers authorised CBAM declarant status. The declaration itself is submitted through the EU CBAM Registry, where you remain the declarant of record. Carbon Mandate does not file. We are a preparer, not a filer: we check every incoming supplier XML against the EU CBAM schema, coordinate the supplier pipeline, and hand your filing team an audit-ready evidence pack to submit yourselves.

Question 3

What happens when a German importer’s suppliers cannot evidence actual emissions?

Accepted Answer

The declaration falls back to default values, which carry a markup: +10% in 2026 under the standard schedule of Regulation (EU) 2025/2621, rising to 20% and 30% in later years (fertilisers are the sole reduced exception). The uplift is applied to the declared embedded factor on every tonne where actual data is missing, and is surrendered in CBAM certificates. Across a German importer’s full multi-sector book, the cost of unevidenced data compounds quickly. Collecting actual supplier data removes the markup.

Germany imports the most CBAM goods: every sector.

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