Positioning
EU Importers are the consumption end of carbon data and the directly liable parties for CBAM
compliance. The platform provides end-to-end support from supplier management to
declaration submission, ensuring that everything after registration is underpinned by platform
technology and professional services — Importers need only complete registration and final
confirmation, with all intermediate steps handled efficiently by the platform.
Module 1: Registration & Compliance Identity Establishment
Importers must complete platform registration, submitting EU entity information, EORI
number, authorised CBAM declarant credentials, and imported commodity categories. The
platform assigns a unique identifier linked to all of the Importer's suppliers, declaration records,
and compliance history, forming a complete compliance identity profile.
Design Principle Alignment : The Importer's compliance identity is the prerequisite for
accessing suppliers' carbon data and submitting CBAM declarations. The unique identifier
ensures all compliance actions are traceable to a verified legal entity.
Module 2: Supplier (Global Manufacturer) Management
Importers can invite their non-EU suppliers to register within the platform, build a supplier
roster, and link to registered Global Manufacturers' carbon data profiles. The platform displays
each supplier's data submission status, data quality rating, and verification progress in real time.
For suppliers that have not yet registered or lack data capability, Importers can commission
Services Providers to coordinate data collection on their behalf.
Design Principle Alignment : The Importer's greatest pain point is data availability from non-
EU suppliers. The platform eliminates this obstacle through the dual pathways of the supplier
management module and proxy data collection services, ensuring the data chain does not break
at the supplier end.
Module 3: CBAM Declaration Preparation & Submission
The platform automatically aggregates all suppliers' verified emissions data, populates
quarterly reports and annual declarations per CBAM regulatory requirements. The system
performs completeness checks, consistency validation, and compliance reviews prior to
submission, flagging potential issues and providing correction recommendations. After
Importer confirmation, declarations are submitted to the EU CBAM Transitional Registry with
one click.
Design Principle Alignment : One-Working-Hour Good Data manifests on the Importer side
as "after registration, declarations are automated." The platform automatically aggregates,
validates, and formats carbon data dispersed across multiple suppliers into regulatory
compliance documents; Importers need only perform final review and confirmation.
Module 4: Carbon Cost Calculation & CBAM Certificate Management
The platform calculates the number of CBAM certificates to be surrendered based on the
embedded emissions of imported goods and the EU carbon price. The system verifies the
authenticity and deductible amount of carbon prices already paid by Global Manufacturers in
the country of origin, automatically applies deductions, and generates a net carbon cost report.
Importers can track certificate purchase, holding, and surrender status within the platform.
Design Principle Alignment : Carbon cost is the economic variable Importers care about most.
The platform integrates complex carbon price calculations, cross-border carbon price
deductions, and certificate management into a single workflow, making financial impact
clearly visible and manageable.
Module 5: Compliance Calendar & Ongoing Management
The platform provides Importers with a year-round CBAM compliance calendar covering
quarterly report deadlines, annual declaration deadlines, certificate purchase windows, and
regulatory update notifications. The system automatically pushes reminders ahead of each
critical milestone. Historical declaration records, document archives, and data version
management are stored centrally, ensuring Importers can instantly retrieve complete
compliance files during regulatory reviews.
Design Principle Alignment : Compliance is not a one-time event but an ongoing process.
Through automated calendar management and comprehensive archive storage, the platform
frees Importers from tedious compliance schedule tracking and reduces the risk of noncompliance
due to oversight.
Module 6: Risk Assessment & Supply Chain Optimisation
Based on suppliers' data quality ratings, emissions intensity, and home-country carbon pricing
levels, the platform generates a supply chain carbon risk heatmap for Importers. Importers can
use this to identify high-carbon-risk suppliers, simulate the impact of supplier substitution or
product mix adjustments on total carbon costs, and support strategic procurement decisions.
Design Principle Alignment : Good Data serves not only compliance but also decision-making.
Supply chain carbon risk visualisation enables Importers to transform CBAM from a passive
cost into a proactive supply chain optimisation tool.
Module 7: Importer-Side Functions Facilitating Regulators' Work
All of the Importer's declaration data, calculation processes, and supporting documents are
fully preserved in the Data Vault and can be accessed directly by regulators upon authorisation.
The system supports one-click generation of standardised compliance data packages for
regulatory review. Any data modifications during the declaration process are automatically
recorded in the audit trail.
Design Principle Alignment : The Data Vault stores not only Global Manufacturer-side
emissions data but also the complete declaration processing history on the Importer side.
Regulators gain end-to-end data visibility — from emission source to final declaration — with
the entire chain auditable.
Module 8: AI-Powered Assistance
The AI Shen Zhu Engine provides Importers with: intelligent matching for optimal supplier
carbon data combination plans, automatic identification of compliance deficiencies in
declaration forms, carbon cost forecasting and scenario simulation, multilingual regulatory
change interpretation, and one-click generation of executive carbon compliance summary
reports.
Design Principle Alignment : AI liberates Importers from the heavy burden of data
aggregation and regulatory interpretation, enabling them to focus on strategic decisions rather
than operational details — embodying the core philosophy of One-Working-Hour.