Trade facilitation implications of carbon‑intensity requirements

Annex B. Preliminary checklist for border-enforced carbon-intensity requirements

This checklist develops the categories identified and outlined in Figure 4.

Scope, identification and applicability at the border

1. Identification of covered goods

• How are goods subject to carbon-intensity requirements identified at the border (tariff codes, product lists, process-based criteria)?

• How are risks of misclassification or fraud addressed?

• How are non-physical or hybrid goods (e.g. electricity, gases, virtual flows) identified and controlled?

2. Determination of applicability

• How is it assessed whether the regulation applies to a given import (e.g. procedures, exemptions, thresholds, end-use)?

• How are de minimis thresholds (e.g. mass-based, value-based, shipment-based) monitored and enforced?

• How are special procedures (transit, inward processing, re-export, temporary admission) treated?

3. Authorisation and eligibility of traders

• Is importer or manufacturer authorisation or registration required, and how is it verified at the border?

• How are imports handled where authorisations are pending, suspended, or revoked?

• How are indirect representatives or intermediaries treated?

Incorporating environmental regulations into core customs tasks and border procedures

4. Import controls and release of goods

• How do carbon-intensity requirements fit into the normal clearance process?

• At which stage(s) of the clearance process are carbon-intensity requirements assessed (pre-arrival, arrival, post-release)?

5. Information exchange with central or competent authorities

• What information must customs transmit to central authorities or regulators (e.g. registries, supervisory bodies)?

• Is transmission real-time, near-real-time, or periodic?

6. Circumvention, evasion and fraud

• What indicators are used to detect circumvention (e.g. rerouting, processing changes)? Can these methodologies incorporate environmental concerns?

• How do customs co-operate with other authorities in investigations?

7. Trader information and compliance support

• How are traders informed of obligations and procedural requirements?

• What guidance, alerts, or system messages are provided at declaration or pre-arrival stages?

• How can/will these systems incorporate carbon intensity?

Data requirements and interoperability

8. Use of existing customs data

• Which standard customs data elements can be reused for carbon intensity checks (e.g. trader identifiers, tariff codes, quantity, origin, procedure codes)?

• How are these data stored, reused and shared across systems?

9. New carbon-related data elements

• Which additional data elements are required (e.g. carbon-intensity values, registry accounts, declarant status)?

• At which stage must they be provided and validated?

10. Data quality and exception handling

• How are missing, inconsistent or incomplete data treated?

• Are defaults, proxies or conservative values applied, and under what conditions? How can they be incorporated into existing customs processes?

11. Confidentiality and sensitivity

• Which data are commercially sensitive or enforcement-sensitive?

• How are access rights, data protection and audit trails managed?

12. System-to-system interaction

• How do customs systems exchange data with other regulatory agencies?

• Which data models, formats and standards underpin interoperability among domestic agencies?

13. Technical constraints

• What limitations exist in legacy IT systems?

• Where is manual intervention required due to lack of automation or verification capability?

Integration with trade facilitation tools

14. Risk management

• How are carbon-intensity requirements integrated into automated risk profiles?

• How is verified vs. unverified information reflected in risk scoring?

15. Pre-arrival processing

• Can carbon-related data be submitted and validated prior to arrival?

• Are early decisions binding or subject to revision?

16. Single Window and inter-agency coordination

• How are responsibilities allocated across customs and other competent authorities?

• Is the “submit-once” principle preserved?

17. Trusted trader / Authorised Economic Operator programmes

• Are carbon-related compliance and verification capabilities reflected in trusted trader status?

• How are facilitation benefits adjusted based on reliability of carbon data?

18. Post-clearance audits

• How are carbon-intensity claims verified ex post?

• Does supply-chain evidence need to be reconstructed across time and jurisdictions? What acceptable methods will there be for doing this?

Capacity, governance and future interoperability

19. Administrative capacity

• What additional human resources and expertise are required for customs and other authorities?

• Which functions require specialised technical or environmental knowledge?

20. Guidance and training

• What guidance is needed for officials and traders?

• How are updates to methodologies or requirements communicated?

21. System development and digital tools

• What system upgrades or new digital tools are required?

• Is interoperability with foreign authorities needed? How will it be implemented?

22. Cross-regulatory coherence

• How can data collected for one regulation be reused for others requiring carbon-intensity information (e.g. product passports, sustainability reporting)?

• How can duplication of reporting and verification be avoided?