60 2024 TSMA er) placing a procurement order to purchase a product through Taiwan’s trading company. The trading company can inquire and buy products at appropriate prices in the market while covering some product information, such as the actual manufacturer or delivering the goods with altered packaging. However, according to the CBAM declaration rules, listed export products shall provide comprehensive information, including manufacturing processes, embedded carbon emissions, energy usage, and even purchased precursor materials, as well as detailed information about the production facility locations and related processing routes. For trading companies, providing such clear and transparent product information to European importers, rather than directly submitting it to the EU CBAM authorities, may result in the loss of trade secrets. Although the CBAM regulations include safeguards for information protection, for European importers, having access to actual manufacturing and processing information could potentially lead to unfair trade results. For example, European businesses might bypass trading companies and directly inquire with manufacturing facilities to reduce procurement costs. The EU authorities might also gain insight into related process emissions and energy efficiency data to set additional production or environmental standards, further influencing relevant businesses’ compliance in the future. For producers, processors, and warehousing entities in domestic or export trade zones, the firms are often uncertain whether their products will be exported to the EU when manufactured or stored. However, under the conditions of the EU CBAM, lacking the relevant embedded carbon emissions documentation or providing sufficient carbon price certificates may lead to varying degrees of trade barriers or even loss of orders. From the perspectives of European importers, consumer products, such as sports industry equipment, are high market substitutability. Risk-potential supply sources with data gaps or penalty concerns will likely be excluded first. The exported products may result in lower prices or even be returned to mitigate operational risks. Therefore, preparing relevant declaration information for future exportation of CBAM-covered products is crucial for global trade operators like Taiwan. Ensuring the completeness of customs documentation and establishing better trade cooperation and marketing conditions is essential to safeguard the business resilience until a resolution is achieved for “non-tariff trade barriers.” Conclusions In light of the critical issues under the CBAM scheme described above, the concept of CBAM is closely integrated with national climate governance, carbon pricing schemes, carbon management, and trade strategies to stand on solid ground. Regarding the business development prospects of energy-intensive industries and sports equipment products affected by CBAM, this study
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