Trojan Special Fasteners Ltd | Specialist Nuts Fasteners | Nuts Bolts Washers | Precision Polygon Turning | Fastener Manufacturer

1.2 Trojan Special Fasteners Position

17. Does Trojan Special Fasteners Limited import goods into the EU?

No. Trojan Special Fasteners Limited does not import goods into the EU and is therefore not a CBAM declarant under Regulation (EU) 2023/956.

What This Means in Practice:

• As Trojan Special Fasteners Limited does not import goods into the EU customs territory, no obligation arises under Regulation (EU) 2023/956 to register as an authorised CBAM declarant, to submit CBAM declarations, or to purchase and surrender CBAM certificates.
• The CBAM obligations fall upon the EU importer, being the person who presents CBAM goods for release into free circulation within the EU customs territory. Where Trojan Special Fasteners Limited supplies products to EU-based customers, it is the EU importer who bears the status and obligations of the CBAM declarant.

Definition of a CBAM Declarant:

• A "CBAM declarant" is defined under Regulation (EU) 2023/956 as a person who, at the time of importation, is either the importer who lodges a customs declaration for release into free circulation in their own name and on their own behalf, or the customs declarant where the customs declaration is lodged by an indirect customs representative. As Trojan Special Fasteners Limited does not perform either of these functions in respect of EU imports, it does not hold this status.

Trojan Special Fasteners Limited's Role in the Supply Chain:

• Trojan Special Fasteners Limited's role is that of a manufacturer and supplier, not an importer into the EU.
• Where its products are purchased by EU customers and imported into the EU, the CBAM declarant is the EU importer, who may be the customer directly or a customs representative acting on the customer's behalf.
• In this context, Trojan Special Fasteners Limited may be approached by EU importers for embedded emissions data to enable those importers to discharge their own CBAM reporting and declaration obligations.

Obligation to Provide Emissions Data:

• Whilst Trojan Special Fasteners Limited is not itself a CBAM declarant, it may have a commercial and practical obligation to provide embedded emissions data to its EU customers.
• The EU importer, as CBAM declarant, is required to declare the embedded emissions in imported CBAM goods. Where actual emissions data from the manufacturer is available, that data must be used in preference to default values.
• Providing accurate and documented emissions data therefore supports EU customers in meeting their obligations under Regulation (EU) 2023/956 and may be a condition of continued commercial relationships with EU-based importers.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

18. Who is responsible for the CBAM declaration when Trojan supplies an EU customer?

When Trojan Special Fasteners Limited supplies products to an EU customer, the responsibility for the CBAM declaration rests with the EU importer, being the person who presents the goods for release into free circulation within the EU customs territory. Trojan Special Fasteners Limited, as the non-EU manufacturer and supplier, bears no declarant responsibility under Regulation (EU) 2023/956.

Definition of the CBAM Declarant:

• Under Article 3 of Regulation (EU) 2023/956, a "CBAM declarant" means one of the following:
• A person who lodges a customs declaration for the release into free circulation of goods in their own name and on their own behalf.
• A person in whose name a customs declaration is lodged, where the declaration is made by an indirect customs representative.
• In both cases, the declarant must be established within the EU and must hold a valid authorisation as an authorised CBAM declarant from the competent authority of an EU Member State before importing CBAM goods in the definitive phase.

The EU Importer as Declarant:

• In a typical transaction where Trojan Special Fasteners Limited supplies nuts or other machined parts to an EU-based customer, the EU customer, or a customs agent acting on the EU customer's behalf, will be the person who lodges the customs declaration for release into free circulation.
• It is this person who holds the status of CBAM declarant and who bears the legal obligations under Regulation (EU) 2023/956, including:
• Holding a valid authorisation as an authorised CBAM declarant from the competent authority of an EU Member State.
• Submitting the annual CBAM declaration by 31 May each year, covering all imports of CBAM goods in the preceding calendar year.
• Purchasing and surrendering CBAM certificates equal to the embedded emissions declared.
• Maintaining the required minimum holding of CBAM certificates in their registry account.

Role of Indirect Customs Representatives:

• Where an EU importer engages an indirect customs representative, such as a freight forwarder or customs broker, to lodge the customs declaration on their behalf, that representative may, in certain circumstances, become the CBAM declarant.
• However, an indirect customs representative may only act as CBAM declarant where the actual importer is not established in the EU or where the representative explicitly accepts that role. In practice, for commercial transactions between Trojan Special Fasteners Limited and EU-established customers, the EU customer is most likely to be the declarant.

Trojan Special Fasteners Limited's Position:

• Trojan Special Fasteners Limited, as a UK-based manufacturer supplying goods to EU customers, is not established within the EU customs territory and does not lodge customs declarations for release into free circulation in the EU.
• It therefore cannot hold the status of authorised CBAM declarant and bears no declarant obligations under Regulation (EU) 2023/956.
• Trojan Special Fasteners Limited's obligation in this context is limited to providing accurate embedded emissions data to its EU customers upon request, to enable those customers to fulfil their own CBAM declaration obligations.

Practical Implications for Trojan Special Fasteners Limited:

• EU customers who are authorised CBAM declarants may request emissions data from Trojan Special Fasteners Limited in order to complete their annual CBAM declarations accurately.
• Where actual emissions data from Trojan Special Fasteners Limited is not provided, the EU importer may be required to use default values published by the European Commission, which are typically set at a conservative level and may overstate the actual embedded emissions, resulting in a higher CBAM certificate obligation for the customer.
• Providing accurate, documented, and verifiable emissions data to EU customers is therefore both a commercial consideration and a means of supporting supply chain compliance under Regulation (EU) 2023/956.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation, Article 3
Commission Implementing Regulation (EU) 2023/1773

19. Why does Trojan provide emissions data if it has no legal reporting obligation?

Whilst Trojan Special Fasteners Limited has no direct legal obligation under Regulation (EU) 2023/956 to report or declare embedded emissions, it provides emissions data to EU customers as a matter of commercial necessity and supply chain responsibility, to enable those customers to fulfil their own obligations as authorised Carbon Border Adjustment Mechanism (CBAM) declarants.

The EU Importer's Dependency on Manufacturer Data:

• The EU importer, as the authorised CBAM declarant, is required to declare the embedded emissions in imported CBAM goods as part of their annual CBAM declaration submitted by 31 May each year.
• Where actual emissions data from the manufacturer is available, that data must be used in preference to default values published by the European Commission (EC).
• Where actual data is not provided by the manufacturer, the EU importer is required to fall back on default values, which are set conservatively and are likely to overstate the actual embedded emissions of machined parts such as those produced by Trojan Special Fasteners Limited.
• This overstating of emissions directly increases the number of CBAM certificates the EU importer must purchase and surrender, resulting in a higher financial cost for the customer.

Commercial Considerations:

• EU customers who are authorised CBAM declarants will have a strong commercial preference for suppliers who can provide accurate, documented, and verifiable emissions data.
• A failure by Trojan Special Fasteners Limited to provide such data may result in EU customers facing higher CBAM certificate costs than necessary, which could damage commercial relationships and place Trojan at a competitive disadvantage relative to other suppliers who do provide emissions data.
• Providing emissions data is therefore a means of protecting and strengthening existing customer relationships and maintaining competitiveness in EU markets.

Nature of the Emissions Data Trojan Provides:

• Trojan Special Fasteners Limited manufactures nuts from pre-produced steel, stainless steel, and aluminium bar using mechanical machining processes only. No metallurgical transformation of the metal occurs.
• The embedded emissions attributable to Trojan's manufacturing stage consist primarily of electricity use in the machining process, as the upstream emissions from bar production are determined by the bar manufacturer rather than Trojan.
• Trojan's emissions data therefore reflects:
• The electricity consumed in its Carbon Numerically Controlled (CNC) turning, drilling, and tapping operations.
• Any minor direct emissions from site energy use.
• The upstream embedded emissions of the bar stock from which the nuts are machined, sourced from the relevant bar supplier or determined by reference to default values where supplier data is unavailable.

Supporting the Integrity of the CBAM:

• By providing accurate emissions data, Trojan Special Fasteners Limited supports the broader objective of the EU CBAM, which is to ensure that the carbon cost embedded in imported goods is accurately reflected and appropriately priced.
• The use of conservative default values in the absence of manufacturer data undermines this objective by overstating emissions and imposing unnecessary costs on EU importers of goods that are in fact produced with lower embedded emissions.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

20. What is Trojan's position on CN 7318 (Nuts and Bolts) as of 2026?

Trojan Special Fasteners Limited adopts a conservative position and treats Combined Nomenclature (CN) 7318 goods, including nuts, bolts, screws, and similar fasteners, as falling within the intended scope of the Carbon Border Adjustment Mechanism (CBAM) from 1 January 2026, whilst acknowledging that the formal legal inclusion of CN 7318 within Annex I of Regulation (EU) 2023/956 is subject to a pending amendment to that Annex.

Current Legal Position of CN 7318:

• Annex I of Regulation (EU) 2023/956 currently lists the CN codes that are within the formal scope of the CBAM.
• CN 7318, which covers screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers, and similar articles of iron or steel, is not currently listed in Annex I as a CBAM good.
• The formal legal scope of the CBAM therefore does not yet extend to CN 7318 goods as at the date of this publication. Downstream iron and steel articles such as those falling under CN 7318 become CBAM goods only when Annex I is formally amended to include them.

The European Commission's Stated Intention:

• The European Commission (EC) has signalled its intention to extend the CBAM to downstream iron and steel products, including CN 7318 goods.
• Draft measures and communications relating to this extension are published on EUR-Lex CBAM Amendments.
• Any formal extension of the CBAM to CN 7318 requires an amendment to Annex I of Regulation (EU) 2023/956 through the appropriate legislative procedure.

Why Trojan Adopts a Conservative Position:

• Trojan Special Fasteners Limited treats CN 7318 goods as within the intended CBAM scope from 1 January 2026 for the following reasons:
• To support EU customers in preparing for the anticipated extension of the CBAM to CN 7318 goods, avoiding a situation where customers are unprepared when the formal amendment is adopted.
• To avoid understating the CBAM exposure of EU customers who import Trojan's products, ensuring that those customers are not caught without adequate emissions data or CBAM certificate holdings when the formal inclusion of CN 7318 takes effect.
• To provide clarity and consistency in its commercial and compliance communications to EU customers.
• To reflect the EC's clearly stated policy direction, which makes the eventual formal inclusion of CN 7318 a foreseeable regulatory development rather than a speculative one.

What This Position Means in Practice:

• Trojan Special Fasteners Limited calculates and makes available embedded emissions data for its CN 7318 products as though those products are already formally within the CBAM scope.
• This data covers:
• Upstream embedded emissions from the production of the steel, stainless steel, or aluminium bar from which the nuts are machined.
• Electricity consumed in Trojan's machining operations, being Carbon Numerically Controlled (CNC) turning, drilling, tapping, and other subtractive processes.
• Any minor direct emissions from site energy use.
• Trojan will update its position immediately upon formal amendment of Annex I of Regulation (EU) 2023/956 to include CN 7318.

Limitations of This Position:

• Trojan's conservative position does not create any legal obligation on EU importers of CN 7318 goods beyond those that arise under the formally adopted legislation.
• Until Annex I is formally amended, EU importers of CN 7318 goods are not legally required to submit CBAM declarations or purchase CBAM certificates in respect of those goods.
• Trojan's position is adopted as a matter of commercial prudence and customer support, and remains legally accurate in that it clearly distinguishes between the current formal legal position and the anticipated future position.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation, Annex I
EUR-Lex CBAM Amendments and Communications

21. Will Trojan update its position if Annex I is formally amended?

Yes. Trojan Special Fasteners Limited has committed to updating its Carbon Border Adjustment Mechanism (CBAM) position immediately upon any formal amendment to Annex I of Regulation (EU) 2023/956 that affects the scope of goods to which the CBAM applies, including any formal inclusion of Combined Nomenclature (CN) 7318 goods.

Why an Annex I Amendment is Significant:

• Annex I of Regulation (EU) 2023/956 defines the goods that are formally within the legal scope of the CBAM by reference to their CN codes and the greenhouse gases relevant to their production.
• Any amendment to Annex I that adds CN 7318 goods would move those goods from their current position of being within the intended but not yet formal scope of the CBAM, to being within the binding legal scope.
• At that point, EU importers of CN 7318 goods would become subject to the full obligations of the definitive phase, including the requirement to hold authorisation as an authorised CBAM declarant, to submit annual CBAM declarations, and to purchase and surrender CBAM certificates.

Trojan's Commitment to Immediate Update:

• Trojan Special Fasteners Limited monitors published amendments to Regulation (EU) 2023/956 and related instruments via the Official Journal of the European Union and EUR-Lex CBAM publications.
• Upon formal amendment of Annex I, Trojan will update its published CBAM position to reflect the change in legal status of CN 7318 goods without delay.
• This update will clearly distinguish between:
• The position that applied prior to the amendment, under which CN 7318 was treated as within the intended but not formally adopted scope.
• The position applying from the date of the amendment, under which CN 7318 is formally within the binding legal scope of the CBAM.

What the Update Will Cover:

• An update to Trojan's position following a formal Annex I amendment may include:
• Confirmation of the CN codes formally brought within scope and the date from which the amendment takes effect.
• Any revised or updated embedded emissions data for affected products, reflecting the formal methodology requirements applicable to the newly included goods.
• Guidance for EU customers on the implications of the formal inclusion of CN 7318 for their own CBAM declaration and certificate obligations.
• Any changes to the emissions data or documentation that Trojan provides to EU customers in light of the amended legal requirements.

Ongoing Monitoring:

• Trojan Special Fasteners Limited recognises that the CBAM is a developing regulatory framework and that further amendments to Annex I, as well as to the implementing acts adopted under Regulation (EU) 2023/956, are anticipated over the coming years.
• Trojan's commitment to updating its position upon formal amendment reflects its broader approach of maintaining accurate, current, and commercially useful CBAM compliance information for its EU customers.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation, Annex I
Official Journal of the European Union
EUR-Lex CBAM Publications

22. How does Trojan define 'embedded emissions' in its reporting?

Trojan Special Fasteners Limited defines embedded emissions in accordance with Regulation (EU) 2023/956, as the greenhouse gases released during the production of goods up to the point of import into the Carbon Border Adjustment Mechanism (CBAM) customs territory of the European Union (EU). In the context of Trojan's manufacturing operations, embedded emissions currently reflect upstream metal production from bar stock only, in line with current European Commission (EC) guidelines.

How This Definition Applies to Trojan's Operations:

• Trojan Special Fasteners Limited manufactures nuts from pre-produced steel, stainless steel, and aluminium bar using subtractive mechanical machining processes, including Carbon Numerically Controlled (CNC) turning, drilling, and tapping.
• Trojan does not melt, cast, forge, roll, or otherwise metallurgically transform metal. Its manufacturing stage therefore generates no metallurgical process emissions.
• In accordance with current EC guidelines, Trojan's embedded emissions reporting currently includes upstream emissions from bar production only, being the emissions generated during the extraction of raw materials and the metallurgical production of the bar stock from which Trojan's nuts are machined.
• These upstream emissions are determined by the production route of the bar supplier, for example whether basic oxygen furnace (BOF) or electric arc furnace (EAF) steelmaking was used, and represent the dominant share of the total embedded emissions of the finished nut.

What Is Currently Excluded:

• In line with current EC guidelines, Trojan's embedded emissions reporting does not currently include:
• Indirect emissions from electricity consumed in Trojan's CNC machining operations.
• Minor direct emissions from site energy use at Trojan's manufacturing facility.
• These components are excluded not because they are immaterial, but because current EC guidelines do not require their inclusion within the embedded emissions boundary for Trojan's manufacturing stage at this time.

Trojan's Readiness for Regulatory Change:

• Trojan Special Fasteners Limited recognises that the CBAM regulatory framework is actively developing and that the treatment of indirect emissions and manufacturing-stage electricity consumption may change as the EC refines its guidelines and methodology.
• Should the regulations change to require the inclusion of indirect emissions, Trojan is prepared to provide indirect emissions data on a per-batch basis, reflecting the electricity consumed in the machining of each specific batch of goods.
• This readiness ensures that EU customers can continue to rely on Trojan as a source of accurate and compliant embedded emissions data without interruption, regardless of how the regulatory requirements evolve.

Boundary of Trojan's Current Emissions Reporting:

• Trojan's current emissions reporting boundary is therefore defined as follows:
• Included: Upstream emissions attributable to the bar stock sourced by Trojan, using bar supplier emissions data where available, or EC default values where supplier data is not available.
• Excluded (currently): Indirect emissions from electricity used in machining and minor direct site emissions, pending any regulatory change requiring their inclusion.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

23. Does Trojan's manufacturing involve 'metallurgical transformation'?

No. Trojan Special Fasteners Limited's manufacturing processes do not involve metallurgical transformation of metal. Trojan manufactures nuts exclusively through subtractive mechanical machining of pre-produced bar stock, which shapes the metal without chemically or structurally altering its fundamental material composition.

What Metallurgical Transformation Means:

• Metallurgical transformation refers to processes that alter the fundamental chemical composition, crystalline structure, or material properties of a metal through the application of heat, pressure, or chemical treatment. Such processes include:
• Melting and casting of raw or scrap metal.
• Forging, which involves the deformation of metal under high pressure, typically with heat.
• Rolling, which reduces metal to flat or shaped products through compressive force.
• Extrusion, which forces metal through a die to produce a continuous profile.
• Smelting and refining of ore or scrap into primary metal.
• These processes generate metallurgical process emissions, being direct Carbon dioxide (CO₂) emissions arising from the chemical reactions and energy consumption inherent in transforming metal at a fundamental level.

Trojan's Manufacturing Processes:

• Trojan Special Fasteners Limited manufactures nuts from pre-produced steel, stainless steel, and aluminium bar using the following processes:
• CNC and automatic turning.
• Drilling.
• Tapping.
• Pressing.
• Other subtractive machining operations.
• These processes remove material from pre-produced bar stock to produce the finished nut. They do not chemically alter the metal, do not involve the application of metallurgical heat treatment, and do not change the fundamental material composition of the bar from which the nut is made.

Significance for Embedded Emissions:

• Because Trojan's operations involve no metallurgical transformation, no metallurgical process emissions arise at Trojan's manufacturing stage.
• There is no separate metallurgical emission factor applicable to Trojan's machining operations.
• The carbon intensity of Trojan's finished nuts is determined principally by the upstream production route of the bar stock, for example whether basic oxygen furnace (BOF) or electric arc furnace (EAF) steelmaking was used by the bar manufacturer, and not by any process occurring at Trojan's facility.
• Trojan's own contribution to the total embedded emissions of its products is limited to electricity consumed in its machining operations, which is currently excluded from reporting under EC guidelines, as set out in question 22.

What This Means for Carbon Border Adjustment Mechanism (CBAM) Reporting:

• The absence of metallurgical transformation at Trojan's facility means that the embedded emissions of Trojan's products are dominated by upstream bar production emissions, with Trojan's manufacturing stage contributing no direct process emissions.
• This is a material consideration for EU customers who are authorised CBAM declarants, as it demonstrates that the embedded emissions attributable to Trojan's manufacturing stage are limited in scope and well-defined in nature.
• It also confirms that Trojan's products do not require a complex multi-stage emissions calculation covering multiple metallurgical processes, simplifying the emissions data that Trojan is able to provide to EU customers.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

24. Is Trojan considered an 'operator' under the EU CBAM definition?

No. Trojan Special Fasteners Limited is not considered an "operator" within the meaning of Regulation (EU) 2023/956. The term "operator" under the Carbon Border Adjustment Mechanism (CBAM) refers to a person operating an installation in a third country where Carbon Border Adjustment Mechanism (CBAM) goods are produced, and is distinct from the role of authorised CBAM declarant. Whilst Trojan manufactures goods in a third country (the United Kingdom (UK)) that may fall within the intended scope of the CBAM, its role under the Regulation is more accurately characterised as that of a third-country manufacturer rather than an operator in the formal sense.

Definition of 'Operator' Under the CBAM:

• Under Article 3 of Regulation (EU) 2023/956, an "operator" means a person who operates or controls an installation in a third country in which CBAM goods are produced.
• The concept of an "installation" in this context refers to a production facility in a third country where CBAM goods are manufactured, and is used principally in the context of the verification and reporting of embedded emissions data by third-country producers.
• The operator is the entity responsible for the accuracy of the production data and embedded emissions information that is passed to the EU importer, who in turn uses that data to fulfil their obligations as an authorised CBAM declarant.

Trojan's Position:

• Trojan Special Fasteners Limited operates a manufacturing facility in the UK, which is a third country for the purposes of Regulation (EU) 2023/956 following the UK's departure from the EU.
• Trojan manufactures nuts from pre-produced steel, stainless steel, and aluminium bar using Computer Numerically Controlled (CNC) machining processes.
• Whilst Trojan could be characterised as operating an installation in a third country where goods that may fall within the intended CBAM scope are produced, it does not hold any formal status or registration under the CBAM as an operator.
• The CBAM does not impose direct obligations on third-country manufacturers in their own right. Obligations under Regulation (EU) 2023/956 are imposed on the authorised CBAM declarant, being the EU importer, who must obtain and use accurate emissions data from the third-country manufacturer to discharge those obligations.

Practical Significance of the Operator Concept for Trojan:

• Although Trojan is not a formal operator under the CBAM, the concept is relevant to Trojan in the following practical respects:
• EU importers of Trojan's products who are authorised CBAM declarants may require Trojan to provide embedded emissions data in a format consistent with the requirements of Regulation (EU) 2023/956 and Commission Implementing Regulation (EU) 2023/1773.
• In the definitive phase, embedded emissions data provided by third-country manufacturers may be subject to verification by an accredited verifier. Trojan should therefore ensure that its emissions data is accurate, documented, and capable of withstanding scrutiny.
• Where Trojan provides emissions data to EU customers, it is acting in a manner analogous to that of an operator supplying data to a declarant, even though it does not hold that formal status under the Regulation.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation, Article 3
Commission Implementing Regulation (EU) 2023/1773

25. How does Trojan support EU customers who are 'Authorised CBAM Declarants'?

Trojan Special Fasteners Limited supports EU customers who hold the status of authorised Carbon Border Adjustment Mechanism (CBAM) declarant under Regulation (EU) 2023/956 by providing accurate, documented, and verifiable embedded emissions data for its products, enabling those customers to fulfil their annual CBAM declaration obligations without recourse to conservative default values published by the European Commission (EC).

Why Authorised CBAM Declarants Need Manufacturer Support:

• An authorised CBAM declarant is a person authorised by the competent authority of an European Union (EU) Member State to import CBAM goods and discharge the associated CBAM obligations in the definitive phase.
• By 31 May each year, an authorised CBAM declarant must submit an annual CBAM declaration covering all imports of CBAM goods in the preceding calendar year, and must surrender CBAM certificates equal to the embedded emissions declared.
• Where actual emissions data from the manufacturer is available, that data must be used in preference to EC default values. Default values are set conservatively and are likely to overstate the actual embedded emissions of machined parts such as those produced by Trojan, resulting in a higher CBAM certificate cost for the customer.
• Trojan's support therefore has a direct and quantifiable financial benefit for EU customers, by reducing the number of CBAM certificates they are required to purchase and surrender.

What Trojan Provides:

• Trojan Special Fasteners Limited provides the following to EU customers who are authorised CBAM declarants:
• Embedded emissions data for its products, currently comprising upstream emissions from the production of the bar stock from which the nuts are machined, in line with current EC guidelines as described in question 22.
• Per-batch emissions data for indirect emissions arising from electricity consumed in Computer Numerically Controlled (CNC) machining operations, available upon request and ready to be provided should the regulatory requirements change to mandate its inclusion.
• Documentation supporting the emissions data provided, to assist EU customers in demonstrating the accuracy and reliability of the data used in their CBAM declarations.
• Prompt updates to emissions data and supporting documentation upon any formal amendment to Annex I of Regulation (EU) 2023/956 or any change to the applicable EC guidelines or implementing acts.

Trojan's Conservative Compliance Position:

• As set out in question 20, Trojan treats Combined Nomenclature (CN) 7318 goods as within the intended CBAM scope from 1 January 2026, in anticipation of a formal amendment to Annex I of Regulation (EU) 2023/956.
• This means that Trojan is already providing emissions data for its CN 7318 products in a format and to a standard consistent with CBAM requirements, so that EU customers are not left without compliant data at the point when formal inclusion takes effect.

Limitations of Trojan's Support:

• Trojan Special Fasteners Limited is not itself an authorised CBAM declarant and cannot discharge the CBAM declaration or certificate obligations on behalf of its EU customers.
• The legal responsibility for submitting accurate CBAM declarations and surrendering the correct number of CBAM certificates rests entirely with the EU importer as the authorised CBAM declarant.
• Trojan's support is limited to the provision of emissions data and documentation. EU customers remain responsible for the accuracy of their own CBAM declarations and for ensuring that the data provided by Trojan is correctly incorporated into those declarations.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

26. Does Trojan maintain an in-house Carbon Border Adjustment Mechanism (CBAM) reporting template?

Yes. Trojan Special Fasteners Limited has developed an in-house data collection and reporting template, designed to capture and present embedded emissions information for its products in a format that can be provided to authorised CBAM declarants, enabling those declarants to fulfil their obligations via the CBAM registry or such other reporting systems as may be required under Regulation (EU) 2023/956 and its associated implementing acts.

Purpose of the Template:

• The primary purpose of Trojan's in-house template is to collect, organise, and present embedded emissions data for its Combined Nomenclature (CN) 7318 products in a consistent, accurate, and readily usable format.
• The template enables EU customers who are authorised CBAM declarants to extract the embedded emissions data they require from Trojan and to input that data into whichever reporting system or registry they are required to use to discharge their own CBAM obligations.
• By providing data in a structured and documented format, Trojan reduces the administrative burden on EU customers and minimises the risk of data errors arising from the transfer of emissions information between Trojan and its customers.

What the Template Captures:

• Trojan's in-house reporting template is designed to capture the following information:
• The identity and description of the goods supplied, including the relevant CN code.
• The upstream embedded emissions attributable to the bar stock from which the nuts are machined, expressed in tonnes of Carbon dioxide (CO₂) equivalent per tonne of goods, in line with current European Commission (EC) guidelines.
• The quantity of goods supplied per batch or consignment.
• The total embedded emissions attributable to the goods supplied, calculated by reference to the upstream emissions data and the quantity of goods.
• Supporting information relating to the bar stock source and production route, for example whether basic oxygen furnace (BOF) or electric arc furnace (EAF) steelmaking was used, where such information is available from the bar supplier.

Readiness for Indirect Emissions Reporting:

• Trojan's template is structured to accommodate the addition of indirect emissions data, being the emissions arising from electricity consumed in Computer Numerically Controlled (CNC) machining operations, on a per-batch basis.
• Whilst indirect emissions are not currently required to be included under EC guidelines, the template is designed so that this data can be added without structural changes, ensuring that Trojan can respond promptly to any regulatory change requiring its inclusion.

How Declarants Use the Data:

• Authorised CBAM declarants who receive embedded emissions data from Trojan via the template may use that data to complete their reporting obligations via:
• The CBAM registry, being the permanent electronic system established by the EC through which authorised CBAM declarants submit annual CBAM declarations and manage their CBAM certificate holdings in the definitive phase.
• Any other reporting system or format prescribed by Regulation (EU) 2023/956 or its implementing acts, as these may be updated or supplemented over time.
• The legal responsibility for the accuracy and completeness of the CBAM declaration submitted via those systems remains with the authorised CBAM declarant. Trojan's template provides the underlying emissions data but does not itself constitute a CBAM declaration.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

27. Are Trojan's UK machining operations included in the EU CBAM system boundary?

Trojan Special Fasteners Limited's United Kingdom (UK) machining operations are not included in the Carbon Border Adjustment Mechanism (CBAM) system boundary as currently defined under Regulation (EU) 2023/956 and current European Commission (EC) guidelines. The embedded emissions attributable to Trojan's machining stage, principally electricity consumed in Computer Numerically Controlled (CNC) operations, are currently excluded from the reporting boundary. Only upstream emissions from bar stock production are currently included.

Definition of the CBAM System Boundary:

• The CBAM system boundary defines which stages of the production process, and which associated emissions, must be included within the calculation of embedded emissions for a given good.
• Under Regulation (EU) 2023/956, embedded emissions are defined as the greenhouse gases released during the production of goods up to the point of import into the EU customs territory.
• In principle, this definition is broad enough to encompass all stages of production, including upstream material production, intermediate processing, and the final manufacturing stage, wherever those stages occur.

Why Trojan's Machining Stage Is Currently Excluded:

• Whilst the definition of embedded emissions in Regulation (EU) 2023/956 is broad in principle, the practical system boundary applied to machined goods such as Combined Nomenclature (CN) 7318 nuts under current EC guidelines does not extend to the indirect emissions arising from electricity consumed at the machining stage.
• Current EC guidelines focus the embedded emissions calculation for machined goods on the upstream production emissions of the bar stock from which the goods are made, as this is where the dominant share of embedded emissions arises.
• Trojan's CNC turning, drilling, tapping, and other subtractive machining operations consume electricity but generate no direct metallurgical process emissions. Under current guidelines, these indirect electricity-related emissions fall outside the required reporting boundary.

The UK as a Third Country:

• Following the UK's departure from the EU, the UK is a third country for the purposes of Regulation (EU) 2023/956.
• The UK does not participate in the EU Emissions Trading System (ETS) and is not listed in Annex III of Regulation (EU) 2023/956 as an excluded country. Goods imported into the EU from the UK are therefore subject to the CBAM in the same manner as goods from any other third country.
• However, the exclusion of Trojan's machining stage from the current system boundary is not a consequence of the UK's third-country status. It reflects the current EC guidelines on the scope of emissions to be included for machined goods, which would apply equally regardless of where the machining operations were located.

What Is Currently Included:

• Under the current system boundary as applied to Trojan's products, the following is included within the embedded emissions calculation:
• Upstream emissions from bar stock production, being the emissions generated during the extraction of raw materials and the metallurgical production of the steel, stainless steel, or aluminium bar from which Trojan's nuts are machined.
• These emissions are determined by reference to bar supplier data where available, or EC default values where supplier data is not available.

Potential for Future Inclusion:

• Trojan Special Fasteners Limited recognises that the EC and UK may revise its guidelines to extend the system boundary to include indirect emissions from electricity consumed at the machining stage.
• Should such a revision occur, Trojan is prepared to provide indirect emissions data on a per-batch basis, as set out in question 22, without interruption to the service provided to EU customers.
• Trojan's in-house reporting template, described in question 26, is already structured to accommodate the addition of indirect emissions data should the system boundary be extended.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773

28. What is Trojan's 'conservative position' regarding downstream articles?

Trojan Special Fasteners Limited adopts a conservative position by treating its Combined Nomenclature (CN) 7318 goods, being nuts and similar fasteners, as falling within the intended scope of the Carbon Border Adjustment Mechanism (CBAM) under Regulation (EU) 2023/956 from 1 January 2026, notwithstanding that CN 7318 has not yet been formally added to Annex I of the Regulation by way of amendment.

What 'Downstream Articles' Means in This Context:

• In the context of the CBAM, "downstream articles" refers to finished or semi-finished goods that are manufactured from primary or intermediate materials that are themselves within the formal scope of the CBAM.
• CN 7318 goods, including nuts, bolts, screws, and similar fasteners of iron or steel, are downstream articles in this sense, as they are manufactured from steel or stainless steel bar, which is itself derived from primary iron and steel production that falls within the current formal scope of the CBAM under Annex I of Regulation (EU) 2023/956.
• The current formal scope of Annex I focuses on upstream and semi-finished iron and steel products rather than finished downstream articles such as fasteners. Downstream articles become CBAM goods only when Annex I is formally amended to include them.

The Basis for Trojan's Conservative Position:

• Trojan's conservative position is adopted on the following grounds:
• The European Commission (EC) has clearly signalled its intention to extend the CBAM to downstream iron and steel products, including CN 7318 goods, making formal inclusion a foreseeable regulatory development.
• Adopting a conservative position now avoids a situation where EU customers are unprepared for the CBAM obligations that will arise upon formal inclusion of CN 7318.
• It avoids the risk of EU customers understating their anticipated CBAM exposure in their own compliance planning and financial forecasting.
• It ensures that Trojan's embedded emissions data is available to EU customers in a compliant format from the outset of formal inclusion, without any delay or interruption.

What the Conservative Position Requires of Trojan:

• In practical terms, Trojan's conservative position requires it to:
• Calculate and maintain embedded emissions data for its CN 7318 products as though those products are already formally within the CBAM scope.
• Provide that data to EU customers upon request, via its in-house reporting template described in question 26.
• Monitor EC communications, draft measures, and amendments published on EUR-Lex relating to the extension of the CBAM to downstream iron and steel products.
• Update its position immediately upon formal amendment of Annex I of Regulation (EU) 2023/956 to include CN 7318.

What the Conservative Position Does Not Do:

• Trojan's conservative position does not create any legal obligation on EU importers of CN 7318 goods beyond those arising under the formally adopted legislation.
• It does not represent a legal interpretation that CN 7318 is currently within the formal binding scope of the CBAM. Trojan clearly distinguishes between the current formal legal position and the anticipated future position in all of its communications.
• It does not affect Trojan's own status under the CBAM, as Trojan is not an authorised CBAM declarant and bears no declaration or certificate obligations regardless of whether CN 7318 is formally within scope.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation, Annex I
EUR-Lex CBAM Publications and Amendments

29. Does Trojan act as an 'indirect customs representative' for its customers?

No. Trojan Special Fasteners Limited does not act as an indirect customs representative for its customers. Trojan's role is solely that of a United Kingdom (UK)-based manufacturer and supplier of machined fasteners. It does not lodge customs declarations on behalf of EU customers, does not hold authorisation as a customs representative, and does not assume any of the legal obligations that arise from acting in that capacity under European Union (EU) customs law.

Definition of an Indirect Customs Representative:

• Under Regulation (EU) 952/2013, the EU Customs Code, a "customs representative" is a person appointed by another person to carry out the acts and formalities required under customs legislation on that person's behalf.
• An indirect customs representative acts in their own name but on behalf of the importer. Critically, an indirect customs representative assumes joint and several liability with the importer for any customs debt arising from the declaration they lodge.
• In the context of the Carbon Border Adjustment Mechanism (CBAM), an indirect customs representative who lodges a customs declaration for the release of CBAM goods into free circulation may, in certain circumstances, be required to act as the authorised CBAM declarant in respect of those goods.

Why Trojan Cannot Act as an Indirect Customs Representative:

• Trojan Special Fasteners Limited is established in the UK, which is a third country for the purposes of EU customs law following the UK's departure from the EU.
• Under Regulation (EU) 952/2013, customs representatives acting before EU customs authorities must generally be established within the EU customs territory.
• Trojan does not hold any authorisation or registration as a customs representative in any EU Member State and does not have the legal standing to act in this capacity.
• Trojan does not lodge customs declarations, does not interact with EU customs authorities on behalf of customers, and does not assume any customs debt or liability in respect of its customers' imports.

Trojan's Actual Role in the Import Process:

• Trojan's role in the supply chain is limited to the following:
• Manufacturing nuts and other machined fasteners from pre-produced bar stock at its UK facility.
• Supplying those goods to EU customers under agreed commercial terms.
• Providing embedded emissions data and documentation to EU customers to assist them in fulfilling their own CBAM obligations as authorised CBAM declarants.
• The act of importing Trojan's goods into the EU customs territory, and all obligations arising from that act under both customs law and the CBAM, rest entirely with the EU customer or their appointed customs representative.

Implications for EU Customers:

• EU customers who import Trojan's goods are responsible for ensuring that they hold, or have appointed a suitably authorised person who holds, the necessary customs and CBAM authorisations to import CBAM goods in the definitive phase.
• Where an EU customer appoints an indirect customs representative to lodge the customs declaration for Trojan's goods, both the customer and the representative should be aware of the circumstances in which the representative may assume the status of authorised CBAM declarant under Regulation (EU) 2023/956.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
EU Customs Code - Regulation (EU) 952/2013

30. How does Trojan's batch-level traceability support CBAM compliance?

Trojan Special Fasteners Limited maintains batch-level traceability for its products, which supports Carbon Border Adjustment Mechanism (CBAM) compliance by enabling accurate, specific, and verifiable embedded emissions data to be provided for each consignment of goods supplied to European Union (EU) customers, rather than relying on generalised averages or conservative default values published by the European Commission (EC).

What Batch-Level Traceability Means:

• Batch-level traceability means that Trojan Special Fasteners Limited is able to identify and record, for each discrete batch of goods manufactured and supplied:
• The specific bar stock material used in production, including its grade, specification, and supplier.
• The production route of the bar stock, for example whether basic oxygen furnace (BOF) or electric arc furnace (EAF) steelmaking was used, where that information is available from the bar supplier.
• The embedded emissions attributable to the upstream bar stock used in that specific batch, expressed in tonnes of Carbon dioxide (CO₂) equivalent per tonne of goods.
• The quantity of goods produced and supplied in that batch.
• The total embedded emissions attributable to that batch, calculated by reference to the upstream emissions data and the quantity of goods.

Why Batch-Level Data Is Important for CBAM Compliance:

• The CBAM obligations of an authorised CBAM declarant are calculated by reference to the actual embedded emissions of the specific goods imported, rather than sector-wide averages or estimates.
• Where actual emissions data from the manufacturer is available, Regulation (EU) 2023/956 requires that data to be used in preference to EC default values.
• EC default values are set conservatively and are likely to overstate the actual embedded emissions of machined fasteners such as those produced by Trojan, as they do not reflect the specific production routes and material sources used by individual manufacturers.
• Batch-level data allows Trojan to provide EU customers with emissions figures that accurately reflect the specific materials and processes used to produce each consignment, rather than a generalised estimate that may significantly overstate the actual carbon intensity of the goods.

How Batch-Level Data Is Captured and Reported:

• Trojan's in-house reporting template, described in question 26, is structured to capture and report embedded emissions data at batch level.
• For each batch supplied to an EU customer, the template records the relevant upstream emissions data for the specific bar stock used, together with the quantity of goods and the resulting total embedded emissions for that batch.
• This data is provided to EU customers in a format that can be directly incorporated into their CBAM declarations via the CBAM registry or such other reporting systems as may be required under Regulation (EU) 2023/956 and its implementing acts.

Support for Verification:

• In the definitive phase, embedded emissions data used in CBAM declarations may be subject to verification by an accredited verifier appointed by the authorised CBAM declarant.
• Batch-level traceability strengthens Trojan's ability to support this verification process by providing a clear and documented audit trail linking the embedded emissions data provided to the specific materials and processes used in each batch.
• This reduces the risk of emissions data being challenged or rejected during verification and supports the overall integrity of the EU customer's CBAM declaration.

Readiness for Indirect Emissions Reporting:

• Should the regulatory requirements change to mandate the inclusion of indirect emissions from electricity consumed in Computer Numerically Controlled (CNC) machining operations, Trojan's batch-level traceability framework is designed to accommodate this addition.
• Indirect emissions data can be calculated and reported on a per-batch basis, reflecting the actual electricity consumed in machining each specific batch of goods, providing the same level of accuracy and specificity as the upstream emissions data currently provided.

Source:

Regulation (EU) 2023/956 - Primary CBAM Regulation
Commission Implementing Regulation (EU) 2023/1773