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EU Climate Initiatives Impacting Non-EU Companies: Stringent ESG Disclosures, Carbon Taxes, Reporting Obligations

Why U.S. Companies Should be Preparing for CSRD and CBAM Compliance Now

Recording of a 90-minute CLE video webinar with Q&A

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Conducted on Wednesday, December 13, 2023

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This CLE webinar will provide a detailed discussion of the recent EU climate initiatives Corporate Sustainability Reporting Directive (CSRD) and Carbon Border Adjustment Mechanism (CBAM) and their far-reaching compliance requirements including stringent ESG disclosures, carbon tax payments, and strict reporting obligations that will also affect non-EU companies. The panel will address which non-EU companies will be affected and when and provide best practices for compliance.


The EU has recently adopted two climate initiatives, CSRD and CBAM, that will begin affecting covered companies--including non-EU and U.S. companies--in the near future. Given the breadth of scope and complexity of each of these initiatives, counsel should take steps now to understand what effect these initiatives may have on their non-EU client companies and how they can best prepare for compliance with the extensive procedural and reporting obligations.

While the CSRD is a European directive, the CSRD is wide reaching and has the potential to affect at least 10,000 non-EU headquartered companies, of which more than 3,000 are U.S. companies. The CSRD's new reporting requirements are voluminous and complex and will require the disclosure of a broader set of ESG topics than the SEC's proposed climate-disclosure rule. The first reporting period begins on Jan. 1, 2024.

Additionally, the CBAM imposes a reporting obligation and carbon tax on the import of certain goods into the EU. The CBAM transition phase and first reporting period are effective Oct. 1, 2023. Companies must report for the first time by Jan. 31, 2024. Exporters into the EU will pay the CBAM based on the embedded emissions of the products they are selling, with a rebate for any carbon price that has already been paid in the country of origin. Exporters to the EU must report the emissions embedded in their products or face hefty fines.

Listen as our expert panel provides a detailed discussion of the CSRD and CBAM and how they will affect non-EU companies. The panel will address what companies may be affected and when and best practices to prepare for and comply with these new climate initiatives.



  1. Overview of EU climate initiatives
  2. CSRD
    1. Purpose
    2. Affected companies
    3. Progressive rollout timeline
    4. Required ESG disclosures
    5. Exemptions
    6. Effect on non-EU/U.S. companies
    7. Penalties for noncompliance
    8. Other considerations
  3. CBAM
    1. Purpose
    2. Affected companies
    3. Transition phase
    4. Covered exports to the EU
    5. Reporting and tax requirements
    6. Effect on non-EU/U.S. companies
    7. Penalties for noncompliance
    8. Other considerations
  4. Best practices for preparation and compliance


The panel will review these and other key issues:

  • What ESG disclosures must be made under CSRD and how do these differ from the proposed SEC rule?
  • What is the progressive rollout timeline for CSRD compliance and what should companies do to prepare for CSRD compliance even if they are not immediately affected?
  • What is the transition phase of CBAM and when will it be fully effective?
  • What CBAM reporting is required of covered companies during the transition phase as compared to when it is fully effective?
  • What are the penalties for CSRD and CBAM noncompliance?


Broome, Shannon
Shannon S. Broome

Partner; California Environmental Practice Group Leader
Hunton Andrews Kurth

Ms. Broome’s prior experience as a chemical engineer in the oil and gas industry affords her unparalleled...  |  Read More

Kloub, Jindrich
Jindrich Kloub

Partner, Head European Antitrust Team
Wilson Sonsini Goodrich & Rosati

Mr. Kloub focuses on complex antitrust investigations, cartel defense, digital markets regulations, and general...  |  Read More

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