EU CBAM Q&A

if you have a specific question you'd like us to address and publish here, please email us at support\@carbonglance com 🇪🇺 cbam declarants what are cbam goods? cbam goods are those falling under the scope of the eu cbam regulation they are identified by their eu cbam q\&a 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 is the reporting period the same for cbam declarants and operators? no although the reporting periods for cbam declarants and operators could align, by default, they differ cbam declarants 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 operators 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 alternative reporting periods may be chosen, provided they cover at least three months and maintain similar levels of data quality common reasons for selecting alternative periods may include the additional scrutiny applied during activities such as stocktaking and financial audits (e g , when the reporting period chosen aligns with the financial year) or third party verification of emissions (e g , when aligning with the reporting period of a carbon pricing scheme applicable to the installation) 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 what is a supplier? 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 what is a consignment? 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 what are the cn codes? the combined nomenclature (cn) is the eu's eight digit coding system, comprising the harmonised system (hs) codes with further eu subdivisions tier number of digits example hs chapter 2 digits 18 cocoa and cocoa preparations hs heading 4 digits 1806 chocolate and other food preparations containing cocoa hs subheading 6 digits 1806 10 cocoa powder, containing added sugar or sweetening matter cn subheading 8 digits 1806 10 15 containing no sucrose or containing less than 5% by weight of sucrose (including invert sugar expressed as sucrose) or isoglucose expressed as sucrose what should i do if i import products with varying embedded emissions under the same cn code, produced at the same installation? 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 🌎 operators what types of ghg emissions are covered for each aggregated goods category? sector aggregated goods category ghg covered cement calcined clay co2 cement cement clinker co2 cement cement co2 cement aluminous cement co2 electricity electricity co2 fertilizers nitric acid co2, n2o fertilizers urea co2 fertilizers ammonia co2 fertilizers mixed fertilizers co2, n2o iron and steel sintered ore co2 iron and steel pig iron co2 iron and steel ferromanganese (femn) co2 iron and steel ferrochromium (fecr) co2 iron and steel ferronickel (feni) co2 iron and steel direct reduced iron (dri) co2 iron and steel crude steel co2 iron and steel iron or steel products co2 aluminium unwrought aluminium co2, pfcs aluminium aluminium products co2, pfcs hydrogen hydrogen co2 what is an installation? 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 what is an aggregated goods category? 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 eu cbam q\&a the aggregated goods categories under the eu cbam are sector aggregated goods category cement calcined clay cement cement clinker cement cement cement aluminous cement electricity electricity fertilizers nitric acid fertilizers urea fertilizers ammonia fertilizers mixed fertilizers iron and steel sintered ore iron and steel pig iron iron and steel ferromanganese (femn) iron and steel ferrochromium (fecr) iron and steel ferronickel (feni) iron and steel direct reduced iron (dri) iron and steel crude steel iron and steel iron or steel products aluminium unwrought aluminium aluminium aluminium products chemicals hydrogen what is a production process? a production process means the parts of an installation in which chemical and/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? if you produce goods from different categories, you must define a separate production process for each category > annex iii, a 4(a) of the cbam implementing regulation if you produce goods within a single category but use different production routes (methods), you must define a separate production process for each route > annex iii, a 4(b) of the cbam implementing regulation 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 what is a production route? 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 fertilizers aggregated goods category production route amonia fertilizers amonia fertilizers iron & steel aggregated goods category production route pig iron iron and steel pig iron iron and steel direct reduced iron (dri) iron and steel direct reduced iron (dri) iron and steel using hydrogen crude steel iron and steel crude steel iron and steel aluminium aggregated goods category production route unwrought aluminium aluminium unwrought aluminium aluminium chemicals aggregated goods category production route hydrogen chemicals hydrogen chemicals hydrogen chemicals hydrogen chemicals hydrogen chemicals docid\ qfwgnaq6zdkeiv2zi m03 what is the bubble approach? general rule if you produce cbam goods under separate aggregated goods categories, you must define a separate production process for each category bubble approach the bubble approach simplifies the general rule by allowing you to define a single production process for goods falling under separate aggregated goods categories this allows you to attribute all inputs from the installation to that process rather than to individual production processes however, the bubble approach is only valid if all precursor goods are used to produce the subsequent cbam good 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 good 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 what are additional qualifying parameters? 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 platform's q\&a to view how to add these parameters cement aggregated goods category additional qualifying parameters calcined clay whether or not the clay is calcined cement clinker none cement clinker content of cement (clinker to cement ratio) aluminous cement none iron & steel aggregated goods category additional qualifying parameters sintered ore none pig iron main reducing agent mass % of mn, cr, ni, other alloy elements ferromanganese (femn) mass % of mn and carbon ferrochromium (fecr) mass % of cr and carbon ferronickel (feni) mass % of ni and carbon direct reduced iron (dri) the main reducing agent used mass % of mn, cr, ni, and other alloy elements crude steel the main reducing agent of the precursor, if known content of alloys in steel, expressed as mass % of mn, cr, ni, and other alloy elements tonnes of scrap used for producing one tonne of crude steel % of scrap that is pre consumer scrap iron or steel products the main reducing agent of the precursor, if known content of alloys in steel, expressed as mass % of mn, cr, ni, and other alloy elements mass % of materials contained which are not iron or steel, if their mass is mote than 1% to 5% of the total good's mass tonnes of scrap used for producing one tonne of crude steel % of scrap that is pre consumer scrap aluminium aggregated goods category additional qualifying parameters unwrought aluminium tonnes of scrap used for producing one tonne of unwrought aluminium product % of scrap that is pre consumer scrap content of alloys in aluminium if the total content of elements other than aluminium exceeds 1%, the total percentage of such elements aluminium products tonnes of scrap used for producing one tonne of the aluminium product % of scrap that is pre consumer scrap content of alloys in aluminium if the total content of elements other than aluminium exceeds 1%, the total percentage of such elements fertilizers aggregated goods category additional qualifying parameters ammonia concentration, if hydrous solution nitric acid concentration (mass %) urea purity (mass % urea contained, % n contained) mixed fertilizers content of different forms of nitrogen in mixed fertilizers content of n as ammonium (nh₄⁺) content of n as nitrate (no3 ) content of n as urea content of n in other (organic) forms what are the eu cbam monitoring principles? how can you find out if you are an operator of an installation producing cbam goods? 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 are emissions from each stage of the supply chain covered by the eu cbam? 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 highest upstream emissions emissions from processes further upstream (e g , mining) transport emissions emissions from transport of materials between sites (e g , emissions from forklifts, trucks, bulldozers, etc ) downstream emissions emissions from use (including distribution) and end of life what are relevant precursors? 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 equations , you obtain the direct and indirect equations of your cbam goods we can also distinguish between external relevant precursors purchased from suppliers internal relevant precursors produced internally (e g , a factory producing both clinker and cement in this case, clinker is a relevant precursor to cement, but instead of being purchased from a supplier, it is produced internally) the embedded emissions of internal relevant precursors will be added to the emissions of the production process in which they are used as input these emissions are calculated based on the quantity of precursors used click examples to view an example what is the difference between relevant precursors and normal input materials? 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 good 🪨 raw material what are intermediate goods? 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 eu cbam q\&a if you purchase any of such goods from external suppliers, you must input them using the 🔩 purchased cbam good docid\ bbhvkana38pedvnnez2q9 form and request the actual emissions data from your suppliers what is tonne of co2e? 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 gas global warming potential unit n2o 265 t co2e/t n2o cf4 6630 t co2e/t cf4 c2f6 11100 t co2e/t c2f6 what is the combined nomenclature (cn)? 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 what is the emission factor? 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) what is the oxidation factor? 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 what is the conversion factor? 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 what are the monitoring approaches under the eu cbam method? calculation based approach 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 standard method this is the most common method emissions are determined by multiplying the amount of fuel or material consumed by specific "calculation factors," primarily the emission factor this calculation can also incorporate additional parameters such as the net calorific value (ncv), oxidation factor, or biomass fraction this method classifies emissions as combustion emissions emissions occurring from the combustion of fuels process emissions emissions occurring from raw materials mass balance typically used for complex installations, such as integrated steel mills, where linking emissions to individual materials is challenging in these processes, outputs like products, by products (e g , slag), and waste contain significant amounts of carbon hence, the mass balance method allows to account for carbon emissions that enter the process but are retained in those outputs rather than being directly emitted into the atmosphere measurement based approach 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 eu cbam q\&a /#what is the emission factor hence, the application of cems always requires two elements measurement of the ghg concentration; measurement of the volumetric flow of the gas stream where the measurement takes place both approaches can co exist at an installation for different parts of the installation, or for mutual corroboration of the same emissions data how does the mass balance work? 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 how is the carbon content for the mass balance method calculated? 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 for fuels if you have the fuel's net calorific value (ncv) and emission factor, you can calculate the carbon content using these values along with the ratio of the molar masses of co2 and c ( f ) when you select a fuel with pre filled calculation factors, our platform will automatically calculate the carbon content based on these values using equations for fuels and materials if you only have the emission factor, the carbon content can be calculated using the emission factor and f when you select a material with pre filled emission factors, our platform will automatically calculate the carbon content based on these values using equations 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 direct input you can directly input the carbon content if you don't have any of the above values what is the difference between the country of origin and country of production? country of origin the "country of origin" is the country or territory in which the last substantial, economically justified processing or working took place, within the meaning of relevant customs legislation (see article 60(2) of regulation 952/2013 , as well as further elaborations on the notion of "last substantial processing or working" in article 32 of the union customs code delegated act (ucc da) 2015/2446 ) in the case of cbam, the non preferential rules of origin apply country of production the "country of production" is the country in which the last physical processing of a cbam good took place (excluding packaging) 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 what are direct emissions? 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 what are indirect emissions? 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 what are embedded emissions? embedded emissions are those released during the production of cbam goods, including the embedded emissions of relevant precursors consumed in the production process what are specific embedded emissions? specific embedded emissions means the embedded emissions of one tonne of goods, expressed as tonnes of co2e emissions per tonne of cbam good what is activity level? 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 do i have to monitor heat streams and emissions? 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 what is a source stream? 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 what is the net calorific value (ncv)? 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 what is the biomass fraction? 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) what is an emission source? 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" what are production subprocesses? 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 subprocess stamping shearing blanking piercing forming trimming bending flanging notching drawing wiping flairing restrike grinding re heating re melting casting hot rolling cold rolling forging pickling annealing plating coating galvanazing wire drawing cutting drilling tapping welding finishing other how are emissions from combined heat & power (chp) calculated? 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 equations , 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 average efficiencies if it is not technically feasible to separately determine the efficiencies of heat and electricity using equations , or if it would incur unreasonable costs, then the options by order of preference are values based on the manufacturer's technical documentation (i e , the design values) conservative standard efficiency values of 55% for heat and 25% for electricity 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 reference efficiencies 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 attribution factors for heat and electricity are computed using those efficiencies to proportion emissions accurately using equations specific emission factors for chp related measurable heat and electricity finally, specific emission factors for chp related heat and electricity are calculated using equations , enabling the allocation of direct and indirect emissions to respective production processes do waste gases have to be considered? 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 iron and steel (blast furnace gas), iron and steel (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 what is considered a waste gas? according to the cbam definition provided in annex ii of the cbam implementing regulation , a ‘waste gas’ means a gas containing incompletely oxidised carbon (usually in the form of co) in a gaseous state under standard conditions which is a result of any of any these processes (a) the chemical, electrolytic or pyrometallurgical reduction of metal compounds in ores, concentrates and secondary materials; (b) the removal of impurities from metals and metal compounds; (c) the decomposition of carbonates, including those used for flue gas cleaning; (d) chemical syntheses of products and intermediate products where the carbon bearing material participates in the reaction; (e) the use of carbon containing additives or raw materials; (f) the chemical or electrolytic reduction of metalloid oxides or non metal oxides such as silicon oxides and phosphates how does the eu cbam differ from the ghg protocol rules? 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 how is biomass treated under the eu cbam? 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? using a certification scheme that provides "proofs of sustainability" and that complies with the requirements of red and the relevant implementing regulation collect all relevant data and perform the necessary calculations by following the steps outlined in the diagram below