Pee Vee Impex solves CBAM’s regulatory hurdle for expansion

The Sustainability Cloud enables Pe Vee Impex to maintain its position as a leading steel manufacturing and exporting hub.

Industry: Manufacturers

Company size: 50+ employees

TSC Solution used: TSC CBAM Solution for Exporters

  • Challenges
  • Lack of knowledge about HSN codes: PEE VEE IMPEX, a leading exporter of Complete Gates, Fences, Railings, Pavilions, Hand Tools, and Wrought Iron Components, faced challenges in understanding CBAM reporting requirements. The company was uncertain about the specific product categories covered under CBAM and initially assumed that emissions data submission was required for all its products. To ensure compliance, PEE VEE IMPEX sought practical guidance on the correct Harmonized System of Nomenclature (HSN) codes applicable under CBAM regulations.
  • Eliminating precursor data challenges: PEE VEE IMPEX faced challenges in obtaining precursor data necessary for accurate CBAM reporting. Its third-party suppliers were unwilling to share the required information, assuming they were not directly subject to CBAM reporting obligations. Collecting precursor data is inherently complex, as it involves multiple stakeholders and entities beyond the reporting company’s direct control, adding to the difficulties in ensuring compliance.
  • Complex production routes: CBAM products encompass various production routes, each contributing to the manufacturing of a single castor. As a result, the company encountered significant challenges in distinguishing between different production routes, collecting accurate data, and effectively segregating relevant information for compliance.
  • Timely compliances: PEE VEE IMPEX encountered significant challenges in meeting the CBAM reporting deadline due to the absence of adequate infrastructure necessary for ensuring timely compliance.
  • Outcome
  • PEE VEE IMPEX successfully identified and categorised CBAM-applicable products by aligning the relevant HSN codes with the European Union’s Combined Nomenclature (CN) codes. With the support of TSC NetZero, a thorough analysis of PEE VEE IMPEX’s product portfolio was conducted to determine the correct CN codes required for CBAM compliance. Following this assessment, PEE VEE IMPEX proceeded with CBAM reporting in accordance with regulatory requirements.
  • The sustainability officers at PEE VEE IMPEX gained a comprehensive understanding of the process for collecting precursor data. They began strategizing and preparing for data collection while developing approaches to effectively engage and persuade suppliers to provide the necessary information for compliance.
  • The Sustainability Cloud facilitated the segregation of various products and the identification of distinct production routes. This differentiation streamlined data collection for each complex product, enhancing accuracy and efficiency. By implementing a robust digital data collection infrastructure and fostering continuous collaboration among multiple suppliers, The Sustainability Cloud enabled seamless integration of diverse production processes through advanced tools and methodologies.
  • With TSC NetZero, the company successfully implemented live tracking and monitoring of emissions data, establishing a robust sustainability framework. Real-time monitoring enabled the early identification of reporting challenges and inconsistencies, allowing for timely resolution and ensuring compliance.

Looking for a solution in the heat of CBAM regulations

An intricate part of modern life, steel commodities and engineering consumables have been woven into our lives in more ways than one. As per World Steel data, 219 kg of steel was used in new products per person globally in 2023. This high consumption of steel has also made it one of the highly exported and imported items. It also entails them to become regulated commodities. However, what happens when the creators of steel consumer durables face sudden regulation that threatens their existing trade routes? 

PEE VEE IMPEX, which specialises in manufacturing and exporting Complete Gates, Fences, Railings, Pavilions, Hand Tools, and Wrought Iron Components, was incorporated as a company in 2008 in Punjab’s Ludhiana. Since then, the company has maintained its status of being a leader in steel manufacturing and exporting to Europe. With advanced infrastructure and skilled staff, the organisation maintained high-quality product delivery while fostering long-term customer relationships.

However, with the implementation of the EU’s Carbon Border Adjustment Mechanism (CBAM), PeeVee Impex faced a significant setback. They were caught in a dilemma during the identification of CBAM products, as per the CN codes published by the EU. They lacked internal systems and mechanisms to clearly understand and segregate CBAM products from non-CBAM items in their main products. Being a business with rapidly expanding operations and increasing business revenues, they were facing a compliance risk that was not under their direct control. 

Getting started with smart Precursor Data Collection

When importers requested PEE VEE IMPEX to share the quarterly emissions data for CBAM reporting, the company faced some significant setbacks in starting the compliance process. The primary challenge stemmed from a lack of clear understanding regarding precursor data collection and inadequate infrastructure for the same. Although the organisation had years of experience in exporting businesses, it did not have any established systems to collaborate on emission data collection with various supplier.


Additionally, third-party suppliers (vendors) were neither prepared with the necessary emissions data nor willing to share it. This reluctance was largely due to their misconception that, since they did not directly export to the EU, they were not obligated to provide such information.


The Sustainability Cloud’s advanced technical expertise in CBAM reporting successfully addressed the challenges associated with precursor data collection. Awareness training sessions and workshops were conducted for PEE VEE IMPEX’s workforce to enhance their understanding of the complexities involved in gathering precursor data. Through tailored consultancy and customised CBAM data-gathering solutions provided by TSC, the company effectively navigated these challenges and strengthened its supply chain network for efficient third-party data collection.

Optimising Production Routes to Reduce Complexity

CBAM-regulated products involve multiple production routes, each playing a role in the manufacturing of a single steel item. Consequently, the company faced considerable challenges in differentiating between these production routes, ensuring accurate data collection, and effectively segregating relevant information for compliance purposes.

The Sustainability Cloud provided essential support by categorising products and identifying distinct production routes. This differentiation optimised data collection processes for complex products, improving both accuracy and efficiency. Through the implementation of a robust digital data collection infrastructure and continuous collaboration with multiple suppliers, The Sustainability Cloud facilitated the seamless integration of diverse production processes using advanced tools and methodologies.

With over 15 years in steel exports to the EU, CBAM posed a significant challenge for us. TSC NetZero simplified the complex CN codes, corrected our reporting errors, and ensured full alignment with importers. Their fast, reliable support helped us meet tight deadlines, map our carbon footprint, and stay on track toward our net zero goals. The software significantly reduced our man-hours and compliance expenses, streamlining operations and improving overall efficiency. TSC NetZero also gave us real-time visibility into our emissions data, allowing us to make informed decisions and improve sustainability performance.

Puneet Bansal
CEO, PEE VEE IMPEX

A deadline that paved the way for business expansion

Pee Vee Impex lacked the necessary systems and resources to facilitate efficient data collection for timely CBAM report submission. The absence of a digital data collection framework, automated precursor data gathering, and comprehensive knowledge of compliance requirements led to delays in quarterly reporting. This situation posed significant risks, including potential customer loss, revenue decline, and a direct threat to the company’s expansion in the EU market.

To address these challenges, The Sustainability Cloud implemented a structured and strategic approach to transform the compliance deadline crisis into a business growth opportunity. The solution was executed in three key steps: first, a comprehensive analysis of the company’s production methods was conducted; second, a rapid deployment of a digital data collection system was undertaken; and third, a thorough information gap analysis was performed. Leveraging its extensive expertise in CBAM reporting, The Sustainability Cloud effectively navigated the complexities of compliance, ensuring a seamless transition. As a result, Pee Vee Impex not only met regulatory deadlines but also successfully expanded its presence in the EU market.