CBAM Goods are those falling under the scope of the EU CBAM Regulation.

They are identified by their Combined Nomenclature (CN) codes listed in Annex I to the CBAM Regulation.

The list can also be found in Annex II, Section 2, Table 1 of the CBAM Implementing Regulation.

No. Although the reporting periods for CBAM Declarants and Operators could align, by default, they differ.

The reporting period for CBAM Declarants is quarterly, which will shift to annual reporting starting in 2026 (CBAM definitive period).

Example:

Transitional Period: For imports of CBAM goods made during Q4 of 2024, the CBAM Declarant must submit a CBAM report by the end of January 2025. For imports made during Q1 of 2025, the CBAM Declarant must submit a CBAM report by the end of April 2025, and so on.

Definitive Period: For imports of CBAM goods made during 2026, the CBAM Declarant must submit a CBAM report by 31 May 2027. For imports of CBAM goods made during 2027, the CBAM Declarant must submit a CBAM report by 31 May 2028, and so on.

The default reporting period for Operators is twelve months, typically based on the (European) calendar year. This is because a full year allows operators to gather data that accurately reflects the annual operations of their installations, including any disruptions from planned shutdowns (e.g., for maintenance) and start-ups. A full year also helps mitigate data gaps, such as by taking meter readings before and after any missing periodic data points.

Example:

For the CBAM reports that an EU company (CBAM Declarant) needs to submit in 2024, they should use suppliers' emissions data measured for the year 2023. For CBAM reports submitted in 2025, they should use suppliers' emissions data measured for the year 2024, and so on.

If a CBAM Declarant is submitting a 2025 Q1 CBAM Report for the imports made during Q4-2024, it can already use the suppliers' emissions data for 2024, provided the supplier has already measured and shared the updated data. However, if the 2024 data is not yet available, emissions data from 2023 could still be used for the Q1 CBAM report. For the remaining 2025 CBAM Reports, the suppliers' 2024 data should be used.

With the term Supplier, we refer to the company that supplies (exports) CBAM goods to the CBAM Declarant (EU Importer). The Supplier is often the Operator of the installation producing the goods, but may also be an intermediary trading company.

A single consignment means products that are either:

(a) Sent simultaneously from one exporter to one consignee; or

(b) Covered by a single transport document covering their shipment from the exporter to the consignee or, in the absence of such document, by a single invoice.

The Combined Nomenclature (CN) is the EU's eight-digit coding system, comprising the Harmonised System (HS) codes with further EU subdivisions.

The CBAM Transitional Registry currently allows reporting at the CN code level. If you import goods with different specific embedded emissions under the same CN code from the same installation, you will need to calculate an average and report it at the CN code level. This is because the Transitional CBAM Registry records embedded emissions by CN code, with no further differentiation at this stage.



An installation means a stationary technical unit where a production process is carried out. In other words, the site or factory where CBAM goods are produced.

The EU CBAM groups goods with different CN codes that can be covered by common monitoring rules under so-called aggregated goods categories. The CN codes falling under each aggregated goods category are defined in Annex II of the CBAM Implementing Regulation.

The general rule is that a separate production process must be defined for each aggregated goods category. However, there are exceptions to this rule.

The aggregated goods categories under the EU CBAM are:

A production process means the parts of an installation in which chemical or physical processes are carried out to produce goods under an aggregated goods category defined in the EU CBAM Implementing Regulation (the table shown above), and its specified system boundaries regarding inputs, outputs and corresponding emissions.

In simpler terms, it's the section of your facility where you manufacture goods that fall under the scope of CBAM, detailing what goes in, what comes out, and the emissions produced during the process.

When do you need to define multiple production processes?

For instance, if you produce unwrought aluminium, which falls under a single aggregated goods category, but produce both primary and secondary (recycled) aluminium, you must define separate production processes for each.

Can you define multiple production processes for goods falling under the same aggregate goods category?

Yes. You can voluntarily choose to monitor different goods or groups of goods within the same aggregated goods category and production route (Annex III, A.4(b) of the CBAM Implementing Regulation).

For example, if the percentages of scrap generated for your products vary, or if you produce finished steel products with different grades or mixed fertilizers with varying fertilizer grades, you may choose to voluntarily establish separate production processes for your goods.

In the graph below, we provide an overview of the different options:

A production route means a specific technology used in a production process to produce goods under an aggregated goods category.

In other words, it refers to the specific technology used in the production of the CBAM goods. For example, in the production of unwrought aluminum, CBAM distinguishes between two production routes: the primary route and the secondary route, the latter being used for recycled aluminum.

Below, we have listed the aggregated goods categories that have more than one production route:

Example:

If you operate an integrated steel mill, the bubble approach allows you to define a single production process for your finished iron or steel products, rather than separate processes for sintered ore, pig iron, crude steel, and iron or steel products. This approach simplifies monitoring, as you can attribute all electricity, fuel, and consumed materials to a single process instead of tracking consumption for each process separately.

In this case, the intermediate goods are not external inputs from another installation but outputs from earlier production stages within your facility that did not need to be defined as separate production processes.

If any precursors, such as sintered ore or pig iron, were sold to third parties instead of being fully consumed in the production of the next CBAM good, the bubble approach would not be permitted.

The additional qualifying parameters offer additional information about the qualities of the CBAM goods, such as the clinker-to-cement ratio or scrap generated per tonne of product. These are outlined in Section 2 of Annex IV to the EU CBAM Implementing Regulation.

Click here to view how to add these parameters.

To answer this question, you must compare the CN codes of your products against the list of goods in Annex I of the CBAM Regulation. If you have received data requests from your clients regarding CBAM, it likely indicates that your products fall under the scope of the Regulation.

You also have at your disposal a CBAM Self Assessment Tool provided by the European Commission on its CBAM website.

Additionally, our Operator tool includes dropdown lists of all CBAM goods, which you can use to identify the goods that fall within scope.

No. The EU CBAM has its own system boundaries because it aims to cover the same emissions that would be covered by the EU Emissions Trading System (ETS) if the production were located in the EU. The system boundaries of emissions covered by the EU ETS, and therefore the EU CBAM, are narrower than those in a product carbon footprint (PCF).

The EU CBAM excludes:

Relevant precursors are input materials that are themselves CBAM goods and have embedded emissions greater than zero.

Our platform refers to these as Purchased CBAM Goods. The emissions associated with your Purchased CBAM Goods will contribute to both your direct and indirect emissions.

Specifically, when adding the embedded emissions of your purchased CBAM goods to your attributed emissions, you obtain the direct and indirect embedded emissions of your CBAM goods.

We can also distinguish between:

Relevant precursors are goods that are themselves covered by the EU CBAM.

When measuring your direct emissions associated with the consumption of normal input materials, you only need to account for the emissions released as a result of processing these materials in your factory - such as emissions from chemical reactions that emit CO2.

For relevant precursors, you must also include the emissions which took place already earlier during their own production, i.e., the precursor’s embedded emissions.

The platform distinguishes between two types of normal input materials:

Intermediate goods are input materials other than CBAM goods that have undergone some form of processing, which distinguishes them from raw materials. For instance, limestone is a raw material, whereas calcined lime is considered an intermediate good.

You will notice that the intermediate goods dropdown list includes some CBAM-covered goods, such as pig iron and direct reduced iron (DRI). These are listed only for cases where you use the bubble approach. If you purchase any of such goods from external suppliers, you must input them using the 🔩 Purchased CBAM Good form and request the actual emissions data from your suppliers.

Tonne of CO2e means one metric tonne of carbon dioxide (CO2), or an amount of any other greenhouse gas listed in Annex I to the EU CBAM Regulation adjusted to the equivalent global warming potential of CO2.

The Combined Nomenclature (CN) is a classification system for goods. It comprises two parts: firstly, a numerical 4-, 6-, or 8-digit number system reflecting different levels of product disaggregation; and secondly, a short text description of each product category, giving its essential characteristics.

The first six digits are identical to the Harmonized System (HS) classification used in international trade, while the remaining two digits are EU-specific additions.

The list of CN codes covered by the EU CBAM can be found in Annex I to the CBAM Regulation.

The emission factor is a coefficient that indicates how much of a specific greenhouse gas (e.g., CO₂, PFCs, N₂O) is released from an activity or process. It is typically measured as the amount of emissions per unit of activity, such as fuel burned, product produced, or energy consumed (commonly measured in terajoules, TJ).

When fuel burns, some of the carbon may form carbon monoxide (CO) instead of fully converting into carbon dioxide (CO₂). The oxidation factor indicates the percentage of carbon that fully converts to CO₂ during combustion. This value must be based on laboratory analyses of your consumed fuel.

If the oxidation factor for carbon is 98%, this means 98% of the carbon in the fuel is fully burned, while 2% remains unburned or turns into something else.

When a material containing carbon undergoes a chemical reaction -such as calcination- the carbon is released into the atmosphere in the form of carbon dioxide (CO₂) or sometimes carbon monoxide (CO). The conversion factor indicates how much of the original carbon in the material is emitted as CO₂ after the reaction. This value must be based on laboratory analyses of your consumed materials.

For example, if the conversion factor is 50%, this means that only 50% of the carbon in the material is converted into CO₂ during the reaction.

In contrast to the measurement-based approach, which is considered a direct way of measuring emissions, the calculation-based approach is considered an indirect way of measuring emissions, since emissions are calculated by taking into account other parameters. The calculation-based approach includes two methods:

This approach is only mandatory for measuring nitrous oxide (N2O) emissions from nitric acid production. It requires installing a continuous emission measurement system (CEMS) at a suitable measurement point, such as a stack. This device monitors the concentration of greenhouse gases (GHGs) and the flow of flue gas for each emission source.

Hence, the application of CEMS always requires two elements:

Both approaches can co-exist at an installation for different parts of the installation, or for mutual corroboration of the same emissions data.

In the mass balance method, all carbon inputs (fuels and raw materials) and outputs (products and wastes) are accounted for, with carbon in products leaving the facility subtracted since it is not emitted.

The molar mass ratio (𝑓) represents the ratio of the molar mass of carbon dioxide (CO₂) to that of carbon (C), expressed as 3.664 t CO₂/t C. This means that for every 1 tonne of carbon burned, approximately 3.664 tonnes of CO₂ are produced because each carbon atom binds with two oxygen atoms, increasing the mass of the resulting CO₂ molecule.

The mass balance approach calculates emissions using the carbon content of the fuel or material. There are three methods to determine carbon content, and our platform supports all of them:

When you select a fuel with pre-filled calculation factors, our platform will automatically calculate the carbon content based on these values using equation 13.

When you select a material with pre-filled emission factors, our platform will automatically calculate the carbon content based on these values using equation 14. Please note that in the case of fuels, you will need to input your own fuel emission factor, expressed in tCO₂/tonne. The one pre-filled will be the one expressed in tCO₂/TJ.

In most cases, "country of origin" and "country of production" will be the same for a given CBAM good, however in some instances they might be distinct.

Direct emissions are those generated by the production processes of CBAM goods, including emissions from the production of heating and cooling consumed during these processes, regardless of the location of the production of the heating and cooling.

Indirect emissions are those generated from the production of electricity consumed during the production of CBAM goods, regardless of the location of the production of the consumed electricity.

Embedded emissions are those released during the production of CBAM goods, including the embedded emissions of relevant precursors consumed in the production process.

Specific embedded emissions means the embedded emissions of one tonne of goods, expressed as tonnes of CO2e emissions per tonne of CBAM good.

Activity level is the total quantity of goods produced within a production process meeting a particular CN product specification for that good, expressed in tonnes or MWh for electricity.

The activity level should take into account saleable products, i.e., products that meet the product specification for an aggregated CN goods category listed in the CBAM Implementing Regulation.

Yes. Only measurable heat should be considered, i.e., heat that is transported through a heat medium such as steam, hot water, liquid salts, etc., and where its flow rate can be measured in pipes, ducts, or similar conduits.

A certain amount of emissions will be attributed to the consumed heat. If the heat is consumed by multiple production processes, you need to monitor the relevant heat streams in order to attribute the correct quantities and heat-related emissions to each production process.

Under the EU CBAM, fuels, materials, or products containing carbon that can be released through combustion or other chemical processes are considered source streams. In other words, a source stream is any fuel, material, or product that, as a result of its consumption or production, releases carbon emissions into the atmosphere.

Note that based on the above definition, a "source stream" can also be a product, by-product, or waste that contains significant amounts of carbon. For instance, slag or waste gases generated during upstream iron and steel production processes that contain carbon qualify as "source streams" even if they are outputs of the process.

When fuel burns, it releases energy. However, some of this energy is lost as water vapor in the combustion process. The NCV tells how much energy is available after accounting for this lost energy.

A higher NCV means a fuel provides more usable energy per unit mass or volume, leading to greater efficiency. This efficiency can result in lower fuel consumption for the same energy output, potentially reducing overall emissions.

The biomass fraction indicates the percentage of the fuel that is composed of organic materials derived from living organisms. For example, if a fuel is made up of 70% biomass (like wood chips or agricultural residues) and 30% fossil fuels, then the biomass fraction is 70%.

Where biomass is used, it may only be "zero-rated" if it fulfills the criteria for zero-rating of biomass emissions as per Section B.3.3 of Annex III of the CBAM Implementing Regulation. Otherwise, the emissions are treated as if they were from fossil sources (go to the General Q&A section for more details).

An "emission source" means a separately identifiable part of an installation or a process within an installation from which relevant greenhouse gases are emitted. In other words, these are individual process units, such as the boiler, the furnace, or the kiln, where greenhouse gas (GHG) emissions are generated.

The stack at your installation could be considered an "emission source". However, that's not where the emissions are actually generated. Therefore, it is more appropriate to label it as an "emission point".

The concept of a production subprocess is not defined or explicitly included in the EU CBAM regulation. However, factory operators could incorporate them to reflect differences in the carbon intensities of goods that undergo processes involving additional inputs and emissions.

Here is a list of subprocess examples:

Combined heat and power (CHP), also referred to as "cogeneration", is the simultaneous generation of heat and power in a single integrated process. Hence, to calculate the emissions associated with CHP using equation 37, it's essential to allocate the total emissions between heat and power outputs.

This allocation requires determining the total fuel input, heat produced, electricity generated, and total emissions from the system. Emissions are calculated based on fuel activity data, net calorific values, and emission factors, including emissions from flue gas cleaning.

If it is not technically feasible to separately determine the efficiencies of heat and electricity using equations 38 and 39, or if it would incur unreasonable costs, then the options by order of preference are:

The efficiency of both heat and electricity production, whether measured, design-based, or using standard values, plays a critical role in this process because it directly influences how emissions are allocated between the two outputs. Higher efficiency means that more useful energy is generated from the same amount of fuel, resulting in lower emissions per unit of energy produced.

The average efficiencies for heat and electricity are then compared against reference efficiencies for standalone heat and electricity production. The reference efficiency values used are for heat production in a stand-alone boiler, and for electricity production without cogeneration. The operator needs to select the appropriate fuel-specific electricity and heat reference efficiency values, which are provided in Tables 1 and 2 in Annex XI of the CBAM Implementing Regulation.

This comparison accounts for the fact that CHP systems are inherently more efficient than separate heat and power generation units because they utilize the same fuel source for both outputs, minimizing energy losses. By benchmarking the CHP system's efficiencies against standard reference values, the calculation can fairly distribute emissions based on how much more (or less) efficiently the CHP operates compared to conventional, separate production systems.

Attribution factors for heat and electricity are computed using those efficiencies to proportion emissions accurately using equations 40 and 41.

Finally, specific emission factors for CHP-related heat and electricity are calculated using equations 42 and 43, enabling the allocation of direct and indirect emissions to respective production processes.

Yes. "Waste gases" are gases that have heating value due to incompletely oxidized fuels. They occur as a result of production processes such as the blast furnace (blast furnace gas), basic oxygen furnace (basic oxygen furnace gas) and coke oven (coke oven gas).

These gases are a mixture of CO2 and incompletely oxidised carbon, usually carbon monoxide (CO), and sometimes hydrogen (H2) and further gases, hence they have an energy content recoverable through use as a fuel, as well as containing "inherent" emissions arising from the production process.

The recovery and use of waste gases as a fuel to produce electricity or heat is preferable over venting or flaring, as this is energy efficient and avoids emissions that would otherwise be produced through combustion of another fuel to produce this energy.

Waste gases are treated with special rules and must be considered in the calculation of your CBAM emissions.

For instance, if waste gas from a blast furnace in an integrated steel mill is reused to generate electricity, the associated emissions are deducted from the pig iron production process and added to the calculation of the electricity's emission factor, which is then used to calculate the indirect emissions.

According to the CBAM definition provided in Annex II of the CBAM Implementing Regulation, a ‘waste gas’ means a gas:

Under the GHG Protocol, emissions from the electricity you produce are classified as direct (Scope 1) emissions. However, under the EU CBAM, these emissions are classified as indirect (Scope 2) emissions.

Similarly, under the GHG Protocol, emissions from heat produced by a supplier are classified as indirect (Scope 2) emissions. However, under the EU CBAM, these emissions are classified as direct (Scope 1) emissions.

Biomass is defined as the biodegradable fraction of products, waste and residues from biological origin from agriculture, including vegetal and animal substances, from forestry and related industries, including fisheries and aquaculture, as well as the biodegradable fraction of waste, including industrial and municipal waste of biological origin.

Where biomass is used, it may only be "zero-rated" if it fulfills the criteria for zero-rating of biomass emissions as per Section B.3.3 of Annex III of the CBAM Implementing Regulation. Otherwise, the emissions are treated as if they were from fossil sources.

These criteria are the ones introduced by the EU in the Recast Renewable Energy Directive (RED II) (sustainability and greenhouse gas (GHG) savings criteria), which is the EU's legal instrument for encouraging the use of renewable energy.

These criteria apply only where biomass is used as a fuel (for energy purposes). Where biomass is used as a process input (e.g., where charcoal is used as reduction agent in a blast furnace or for producing electrodes), such material may always be zero-rated without applying RED II criteria.

How to demonstrate compliance with RED II criteria?