
CBAM Compliance Gap Assessment
EU Regulation 2023/956 | Transitional Phase Reporting
Client / Challenge
Novelis — Global aluminium rolled products manufacturer, ~4.2Mt annual shipments to EU under CBAM scope (CN 7606, 7607, 7604). Novelis faced significant future CBAM exposure on aluminium sheet and foil exports. With the transitional phase reporting in effect and default values expiring end-2026, the client needed a comprehensive readiness assessment against EU Regulation 2023/956 and all 8 implementing acts to identify gaps and build a remediation roadmap.
Approach
- Mapped 340+ CN codes against CBAM product scope, defining last substantial transformation for each product line
- Assessed embedded emissions MRV infrastructure (direct + indirect + precursor tracking) against Commission MRR
- Mapped declarant registration pathways (direct vs. EU-established representative)
- Benchmarked current protocols against default values and future accredited verifier requirements
Outcome
- Identified 14 priority gaps across data collection, system boundaries, and electricity emission factor verification
- Delivered a phased compliance roadmap with Q1–Q4 milestones enabling transition from default values to actual emissions reporting by Q3 2026 (forecasted)
- Estimated €18M annual CBAM liability reduction through verified primary data replacing default emission factors


