Product Footprint Extension for CBAM

1. Introduction

The Technical Specifications for PCF Data Exchange is an excellent interface for collecting GHG emissions data from suppliers because it is very compact and easy to understand for companies reporting GHG emissions and solution vendors providing GHG emissions management services, and does not impose any system components.

The granularity of the "Technical Specifications for PCF Data Exchange" data model, ProductFootprint, is at the product level, allowing for detailed definition of emissions, such as fossil fuel-derived and bio-derived. However, depending on the reporting destination, emissions may be required to be further categorized. CBAM requires reporting to be broadly divided into direct and indirect emissions.

A simple way to express this would be to generate two ProductFootprints, but in that case, it would be necessary to indicate whether the emissions are direct or indirect using, for example, the comment property. However, because the comment property is free-form, any inconsistencies in the expression can make mechanical processing difficult. Therefore, we use the extensions property of ProductFootprint to link direct and indirect emissions to a single ProductFootprint. This is the purpose of this specification.

2. Disclaimer

The data model described in this document is intended to share design intent among stakeholders and does not guarantee any implementation. The contents of this specification are subject to change without notice. The entity names, attribute names, types, constraints, relationships, and other elements described in this document are reference information for design purposes only, and do not guarantee implementation in any particular database product or middleware. Neither Booost, Inc. nor the author of this document accepts any liability for damages arising from any system or application built based on this specification.

3. Constraints

This specification aims to comprehensively cover the data required for CBAM reporting and collect it from suppliers. However, the data included in CBAM reports is diverse and requires regulatory authorities to develop physical specifications (currently, the only reference available is the XSD for quarterly reports). Therefore, the initial version of the data model will focus on direct emissions and associated indirect emissions, which are required properties of CBAM reports. Information provided by reporters is not subject to data exchange, so it will be excluded. Furthermore, information on production methods, supporting documentation, and carbon pricing are not required, and use cases have not been finalized. These will be redefined once they are clarified in the implementation regulations in the future.

While we would like to use as much of the information that can be deterministically expressed in ProductFootprint as possible, we must at least make it possible to set "CBAM" (or a value representing it) as a value for the crossSectoralStandards property. However, this is not within the scope of this specification and should be addressed in the "Technical Specifications for PCF Data Exchange," so we plan to make a separate proposal.

4. Challenges

CBAM reporting requires emissions directly related to the production of exported goods (CBAM products) and emissions directly related to the production of intermediate products that are their precursors. If the reporting importer or indirect customs agent knows the data-holding company, they can collect the data via the REST API described in the "Technical Specifications for PCF Data Exchange." However, if the data-holding company is not a direct business partner, the REST API cannot be used.

One solution to this issue would be to define the data-holding company’s information and emissions in ProductFootprint extensions. However, in this case, downstream companies would transmit the data beyond the rights of the data-holding company. This could violate data sovereignty.

Another solution would be to provide a neutral service that can cross the supply chain and, with permission from the data-holding company, allow reporters to obtain information originating from their own products solely for reporting purposes. In this case, if the data-holding company were to store the data in a neutral service, the data would ultimately be fragmented, making data sovereignty impossible. Therefore, the neutral service would have to be designed to focus solely on data integration.

The above services are currently being developed separately and are expected to form a complete CBAM solution in conjunction with this specification.

5. Data Model

The data model defined in this specification is intended to be included in the ProductFootprint extensions. For details on the data model elements of extensions, see the Technical Specification for Data Model Extensions.

The following extensions allow you to define the direct and indirect emissions required for CBAM reporting. However, the sum of these values ​​must be consistent with properties such as the pcfExcludingBiogenicUptake property of ProductFootprint. Furthermore, the companyIds of ProductFootprint must represent precursor manufacturing facilities, and the productIds must represent precursors identifiable by their delivery destination.

5.1. ProductFootprint Extensions

When defining data according to this specification, you must add data in the following format to the ProductFootprint extensions.

(M/O: Mandatory/Optional)

5.2. CbamExtension

To avoid misunderstandings, property names and constant values ​​have followed the CBAM physical specifications as much as possible.

As noted in the constraints, this data model currently covers at least the items required for CBAM reports, but is not comprehensive. The remaining optional items will be added as necessary.

(M/O: Mandatory/Optional)

5.3. DirectEmissions

Direct emissions are data on the intensity of direct GHG emissions from the fuel combustion process and chemical reaction processes involved in the production of the reported product or its precursor.

(M/O: Mandatory/Optional)

5.4. IndirectEmissions

Direct emissions are data on the intensity of direct GHG emissions from the fuel combustion process and chemical reaction processes involved in the production of the reported product or its precursor.

(M/O: Mandatory/Optional)