General Q&A
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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).
- 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).
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.
An 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 defines in the EU CBAM Implementing Regulation (CBAM goods), and its specified system boundaries regarding inputs, outputs and corresponding emissions.
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.
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.
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:
- Most 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 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 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.
Relevant precursors are input materials that are themselves CBAM goods and have embedded emissions not equal to zero.
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 precursorโs embedded emissions.
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 |
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.
Calculation-based approach: This is considered an indirect way of measuring emissions, since they are calculated by taking into account other parameters. The calculation-based approach has two variants:
- Standard method: This is the most common approach to measuring direct emissions. 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 emission source.
Both approaches can co-exist at an installation for different parts of the installation, or for mutual corroboration of the same emissions data.
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. "Waste gases" are gases that have heating value due to incompletely oxidized fuels and occur as a result of production processes such as the blast furnace of a steel plant. These 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.
The fuels or materials containing carbon that can be released by combustion or other chemical processes (e.g., calcination) are summarized under the EU CBAM by the term "source stream". In simple terms, a source stream is any fuel or material that your installation processes in any of its machinery (e.g., boiler, dryer, kiln, etc.) and as a result of this processing, carbon emissions are released to 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.
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 consistent to label it as an "emission point".