抄録
Secondary steel and aluminum products, such as screws and bolts, are often exported either as components in Japanese-manufactured goods produced in Europe or as spare parts for products originally manufactured in Europe and re-exported there. These products undergo a variety of complex processing steps after the initial steelmaking and aluminum refining stages. These steps may include cold rolling, hot rolling, wire drawing, heat treatments such as annealing, and surface treatments like plating. Furthermore, the distribution of these highly varied products often involves multiple trading companies, adding complexity to the supply chain. As a result, accurately measuring the embedded emissions associated with these secondary products can be costly. Given the relatively small additional weight, value, and emissions associated with these components, the cost of compliance with regulatory requirements is likely to be disproportionately high. Currently, the Communication Template and OC3I portal provided by the EU do not reflect the complexity of the manufacturing processes and commercial transactions involved in secondary steel and aluminum products. This paper highlights the various challenges faced by manufacturers of these secondary products in third countries, as well as by the finished product manufacturers who use them, within CBAM-related supply chains. These insights are based on findings from a study funded by the Ministry of Economy, Trade and Industry. The paper also proposes specific measures that are considered necessary for the effective implementation of the CBAM system by the EU.
