CBAM
Your CBAM declaration rests on data produced in someone else’s factory.
The declarant carries the obligation. The records are generated upstream. The legal question is what connects them.
The gap between obligation
and evidence.
Production records may have been designed for accounting, rather than emissions reporting, in a jurisdiction with its own rules on what they contain and who may see them. When a figure is questioned, the questions become legal: was the supplier obliged to produce it, what was warranted, and what happens to the contract if the figure cannot be supported?
This firm advises on that gap from the Indonesian side.
Four questions to put
to your records.
- What is the supplier contractually required to deliver, and by when?
- Can the production records support the figures being reported?
- Who carries the liability when a warranty about the data fails?
- Which data must be disclosed, and on what legal basis?
Legal work around
the data.
From the supply contract to the record behind the declaration.
- Supply contract review: data provision, warranties, audit rights, and remedies for unsupportable figures.
- Legal assessment of whether an Indonesian supplier’s records can support the reported figures.
- Data provision and cooperation clauses enforceable under Indonesian law.
- Counterparty legal due diligence on Indonesian suppliers of CBAM-scope goods.
- Advice to Indonesian producers on what the applicable obligation requires.
A clear division of responsibility
We do not verify emissions data, calculate emissions, or issue verification statements. We address the law around the data.
Start with the question in front of you.
Tell us about your position in the supply chain and the needs or obligations you must address.