Guidance Document On CBAM Implementation For Importers of Goods Into The EU

EUROPEAN COMMISSION
DIRECTORATE-GENERAL
TAXATION AND CUSTOMS UNION
Indirect Taxation and Tax Administration
CBAM, Energy and Green Taxation
Brussels, 13 December 2023
GUIDANCE DOCUMENT ON CBAM IMPLEMENTATION FOR

IMPORTERS OF GOODS INTO THE EU
This guidance document represents the views of the European Commission Services at the
time of publication. It is not legally binding.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

VERSION HISTORY
Date Version notes

17 Aug 2023 First Publication
27 Oct 2023 The following corrections were made:
• Updates in section 6.3 (reporting template).
• Various typos and references corrected.
21 Nov 2023 Correction on de minimis rule
8 Dec 2023 The following corrections were made :
• Clarifications in section 4.3 (Transitional period), in particular
sections 4.3.4 (Reporting periods) and 4.3.6 (Inward Processing).
• Clarifications in section 5.4.3 (hydrogen) to include other
production routes, to Figure 5-6 (Sintered ore) and to Figure 5-11
(Crude steel-Basic oxygen steelmaking).
• The inclusion of equation reference numbers, in section 6.1.4 that
refer to the Implementing Regulation (EU) 2023/1773.
• Clarification in section 6.2.2 (Reporting the quality of certain
goods imported).
• In section 7 correction to the EFTA exemption rule.
• Deletion of the Annex on Default Values, as this information can
be found on the European Commission’s dedicated website for
the CBAM.
2
CONTENTS
1 SUMMARY 5
2 INTRODUCTION 6
2.1 About this document 6
2.2 How to use this document 7
2.3 Where to find further information 7
3 QUICK GUIDE FOR IMPORTERS 10
4 THE CARBON BORDER ADJUSTMENT MECHANISM 15
4.1 Introduction to the CBAM 15
4.2 Definitions and scope of emissions covered in the CBAM 16
4.3 Transitional period 17

4.3.1 Key reporting roles and responsibilities 18
4.3.2 What needs to be monitored by operators 19
4.3.3 What needs to be reported by reporting declarants 20
4.3.4 Reporting periods for operators and importers 21
4.3.5 Governance of the CBAM 23
4.3.6 Inward processing 24
5 CBAM GOODS AND PRODUCTION ROUTES 26
5.1 Foreword to sector specific sections 26
5.2 Identifying CBAM goods 26

5.2.1 Product specifications 27
5.2.2 Identifying goods in scope for the CBAM Regulation 27
5.3 Cement sector 28

5.3.1 Unit of production and embedded emissions for industry sector 28
5.3.2 Definition and explanation of goods covered 29
5.3.3 Definition and explanation of relevant production processes and routes 30
5.3.4 Additional reporting parameters 33
5.4 Chemicals sector – Hydrogen 34

5.4.1 Unit of production and embedded emissions 34
5.4.2 Definition and explanation of sector CBAM goods covered 35
5.5 Fertilizers sector 37

3
5.6 Iron and Steel sector 43
5.6.3 Definition and explanation of relevant production processes and emissions
covered 49
5.7 Aluminium sector 60

5.7.2 Definition and explanation of sector goods covered 61
6 REPORTING OBLIGATIONS 68
6.1.1 Reporting direct and indirect embedded emissions 68
6.1.2 Units for reporting embedded emissions 68
6.1.3 Embedded emissions 69
6.1.4 Indirect emissions 70
6.1.5 Adding precursor emissions 71
6.1.6 Default emission factors for precursors 72
6.2 Reporting requirements 73

6.2.1 Reporting the quantity of goods imported 73
6.2.2 Reporting the quality of certain goods imported 73
6.2.3 Reporting direct and indirect embedded emissions 74
6.2.4 Units for reporting embedded emissions 75
6.2.5 Reporting the effective carbon price due 75
6.2.6 Information relevant for importers 77
6.3 Reporting template 78

6.3.1 Emission data communication from operators 78
6.3.2 Reporting by declarants 82
7 EXEMPTIONS FROM THE CBAM 87
ANNEX A LIST OF ABBREVIATIONS 88
ANNEX B LIST OF DEFINITIONS 90
4
1 SUMMARY
The Carbon Border Adjustment Mechanism (CBAM) is an environmental policy

instrument designed to apply the same carbon costs to imported products as would be
incurred by installations operating in the European Union (EU). In doing so, the CBAM
reduces the risk of the EU's climate objectives being undermined by production relocating
to countries with less ambitious decarbonisation policies (so-called ‘carbon leakage’).
Under the CBAM, in its definitive (post-transitional) period EU authorised declarants

representing the importers of certain goods will purchase and surrender CBAM certificates
for the embedded emissions of their imported goods. As the price for those certificates will
derive from the EU Emission Trading System (EU ETS) allowance price, and since
Monitoring, Reporting and Verification (MRV) rules have been designed based on the
MRV system of the EU ETS, this will equalise the price of carbon incurred between
imported goods and goods produced in installations participating in the EU ETS.
This guidance document is part of a series of guidance documents and electronic templates
provided by the European Commission to support the harmonised implementation of the
CBAM during the transitional period (1 October 2023 to 31 December 2025). It
provides an introduction to the CBAM and the concepts to be used for reporting of
embedded emissions of goods imported into the EU. This guidance does not add to the
mandatory requirements of the CBAM, but it is aimed at assisting correct interpretation to
facilitate implementation.
This guidance document represents the views of the European Commission Services at the
time of publication. It is not legally binding.
5
2 INTRODUCTION
2.1 About this document
This document has been written to support stakeholders by explaining the requirements of
the CBAM Regulation in a non-legislative language. This guidance focuses on the
requirements for importers of CBAM goods into the EU for the transitional period,
from 1 October 2023 to 31 December 2025, during which time the CBAM is applied
without a financial obligation for importers and solely for data collection purposes.
• Chapter 3 provides a quick guidance for the intended reader of this document, the
importer of CBAM goods and/ or reporting declarant. It gives a roadmap to the
most important concepts of CBAM reporting and where to find more information
in this document.
• Chapter 4 provides an introduction to the CBAM and an overview of the

compliance cycle, roles and responsibilities and milestones and deadlines for
reporting declarants during the transitional period.
• Chapter 5 presents an overview of the goods and value chains for the sectors and
goods that are included in the scope of the CBAM.
• Chapter 6 sets out the reporting obligations and recommendations which are
potentially applicable to any affected importer of CBAM goods.
• Chapter 7 explains the general exemptions from the CBAM.
A separate guidance document is provided by the European Commission for third country
operators of installations producing CBAM goods (herein referred to as “operators”). The
guidance documents are accompanied by an electronic template for information that may
be used by installation operators to communicate information on the embedded emissions
of their goods to the reporting declarants.
Presentation of numbers in EU documents
To align with EU legal documents, this guidance document uses the following
convention when presenting numbers.
The decimal separator used to separate the integral part of a number from its fractional
part is a comma, e.g.: 0,890
Thousands, and powers of 103n thereafter, are separated by a space, e.g.:
• fifteen thousand is written as 15 000
• fifteen million is written as 15 000 000
6
2.2 How to use this document
Where article numbers are given in this document without further specification, they
always refer to the CBAM Regulation 1. Where the ‘Implementing Regulation’ is cited, it
means the Regulation 2 which sets out the detailed monitoring and reporting rules for the
transitional period. For acronyms and definitions used in this document, please see Annex
A and Annex B.
A series of icons are used throughout to help guide the reader:
Icon Description of use
Points to information of particular importance for importers and

reporting declarants.
Simplified! Highlights simplified approaches of the general requirements of

the CBAM.
Used where recommended improvements are presented
Used where other documents, templates or electronic tools are

available from other sources
Points to examples given for the topics discussed in the

surrounding text
Highlights sections that refer to the definitive period of the

CBAM, rather than the transitional period
2.3 Where to find further information
The textbox below signposts the key sections of the CBAM Regulation and the
Implementing Regulation that are relevant to importers of CBAM goods during the
transitional period.
1
Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing
a carbon border adjustment mechanism; Available from: http://data.europa.eu/eli/reg/2023/956/oj
2
Commission Implementing Regulation (EU) 2023/1773 of 17 August 2023 laying down the rules for
the application of Regulation (EU) 2023/956 of the European Parliament and of the Council as regards
reporting obligations for the purposes of the carbon border adjustment mechanism during the transitional
period; available from: http://data.europa.eu/eli/reg_impl/2023/1773/oj
7
The CBAM Regulation
Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May
2023 establishing a carbon border adjustment mechanism.
Available from: http://data.europa.eu/eli/reg/2023/956/oj
• Article 2 – sets out the scope of the CBAM with reference to Annex I.
• Article 3 and Annex IV – provide definitions for common terms used in the
CBAM.
• Articles 5 and 17 – sets out requirements for application for the status of
authorised CBAM declarant, by importers or their indirect customs
representative, to import goods, and for the authorisation by the relevant
Member State. (Apply from 31 December 2024).
• Article 10 – sets out requirements for operator registration under the CBAM
(from 31 December 2024).
• Article 11 – requires Member States to designate a competent authority and
for the European Commission to publish the list of competent authorities and
include it in the CBAM registry.
• Articles 14 and 16 – requires the European Commission to establish a CBAM
registry of authorised CBAM declarants and to assign an account to each
authorised declarant. (Apply from 31 December 2024).
• Article 30 – requires the European Commission to undertake a review of the
scope of the CBAM by 31 December 2024.
• Articles 32 to 35 – set out the reporting obligations on EU importers in the
transitional period.
• Article 36 – sets out the dates from when the other articles start to apply.
• Annex I – provides the list of CBAM goods by industry sector with CN code
to identify goods, and the corresponding relevant greenhouse gases.
• Annex III – identifies the non-EU countries and territories that are not covered
by the CBAM.
• Annex IV – provides the general methods for calculating the embedded
emissions in goods; in section 2 for Simple Goods and in section 3 for
Complex Goods.
Implementing Regulation (EU) 2023/1773: Commission Implementing

Regulation (EU) 2023/1773, available from:
http://data.europa.eu/eli/reg_impl/2023/1773/oj
• Article 2 and Annex II Section 1 – provide definitions for common terms

used in the CBAM and the MRV rules.
• Article 3 – provides the reporting obligations of the reporting declarants,
including the parameters for which data is to be reported.
• Articles 4 and 5 – set out the approaches for the calculation of the embedded
emissions and conditions for the use of default values.
8
• Article 6 – presents the requirements for reporting regarding inward
processing.
• Article 7 – indicates the information to be reported regarding the carbon price
due.
• Articles 8, 9 and 13 – relate to the obligations of the reporting declarant for
submission and modification of the CBAM reports.
• Article 16 – relates to the penalties that shall be applied by Member States if
the reporting declarant has not correctly fulfilled its reporting obligations.
• Articles 19 and 22 – set out technical elements of the CBAM Transitional
Registry.
• Annex I: Table 1 - CBAM Report Structure, Table 2 - Detailed information
requirements in the CBAM report.
• Annex II: Section 2, Table 1 – mapping of CN codes to the CBAM aggregated
goods categories; and Section 3 – definition of production processes for the
CBAM goods categories, including system boundaries of production routes
and relevant precursors.
• Annex IV: Minimum data to be reported by producers of goods (“operators”)
to importers (or reporting declarants).
• Annexes V to VII: Tables listing data requirements for other reports,
including for inward processing (by importers), EORI and the National Import
System.
• Annex VIII: Standard factors that may be used for the monitoring of direct
emissions.
All EU legislation can be found on: eur-lex.europa.eu/homepage.html
Other guidance and training materials that have been produced by the European
Commission to help operators and importers include:
• A separate guidance document is provided by the European Commission for

operators of non-EU installations producing CBAM goods.
• Guidance developed for importers on how to complete quarterly reports on the
CBAM Trader Portal.
• Excel-based template for operators to automatically calculate embedded
emissions and communicate this data clearly to importers of goods.
• Training videos.
The guidance documents and template are available on the dedicated website for the
CBAM of the European Commission: https://taxation-customs.ec.europa.eu/carbon-
border-adjustment-mechanism_en
9
3 QUICK GUIDE FOR IMPORTERS
This section provides a step-by-step overview of important concepts, rules and obligations
under the transitional period.
Are you an importer of CBAM goods? CBAM goods are goods currently imported into
the EU from the cement, iron and steel, aluminium and some chemical industries
(fertilizers and hydrogen), and electricity. To answer this question, you must compare the
CN codes 3 of your imported products against the list of goods given in Annex I to the
CBAM Regulation. More information on how to approach this can be found in Section 5.2
of this document, and subsequent sub-sections 5.3 to 5.7, set out further detail for each
sector.
If you do not import such goods, you do not need read this document. However, it is written
to be of help also to all other kinds of interested audiences (academia, GHG verifiers,
competent authorities, consultants, etc.). If you just want to understand how the CBAM
works in general, you may find an introduction to the CBAM in Section 4.
What are embedded emissions? The concept has been developed to reflect as much as
possible the way in which emissions are covered by the EU ETS as if the CBAM goods
were produced in the EU. The EU ETS requires operators to pay a price for their own
(“direct”) emissions. However, if they consume electricity, they also experience the CO2
costs included in the price of electricity they purchase 4 (“indirect emissions”). The same
applies to the input materials needed for their production process, and which may be
supplied by an EU ETS installation. These so-called precursors therefore contribute to the
CO2 costs the EU ETS installation faces. The “embedded emissions” are defined in parallel
to the emissions causing CO2 costs in the EU ETS: they take into account the direct and
indirect 5 emissions of the production process as well as the embedded emissions of
precursors. The scope of the CBAM is principally related to the rules of the EU ETS and
therefore has differences to other methods for calculating product carbon footprints such
as the “GHG Protocol” or ISO 14067. A detailed introduction to the concept and
calculation of embedded emissions is given in section 6.1.3.
What information do you need to request from the operator of the installation
producing goods you import, in order to be able to report? To answer this question,
you need to perform the following steps.
• Step 1: Define the CBAM goods imported and make sure you understand how they
map to each “aggregated goods category” (i.e. an aggregation of CBAM goods with
different CN codes, but suitable to be covered by common monitoring rules)
• Step 2: Identify all the parameters you need to request from the operator and to
report on:
o Direct emissions of the installation: the operator has two options available:
3
CN (Common Nomenclature) codes are the EU version of the HS (Harmonised System) codes for
international trade. CN codes consist usually of 8 digits (the first 6 digits are identical to the HS code).
Where Annex I to the CBAM Regulation contains fewer digits, it means that all CN codes starting with
those digits are covered.
4
If the EU installation produces its own electricity, it experiences the CO2 costs immediately.
5
Indirect emissions have to be reported for all CBAM goods during the transitional period, although at
this stage only a smaller number of goods is included in Annex II to the CBAM Regulation, i.e. only
those will have to cover indirect emissions in the definitive period.
10
a) The “calculation-based” approach, which uses the quantities of all fuels
and relevant materials 6 consumed, and corresponding “calculation factors”
(in particular the so-called “emission factor” based on the carbon content of
the fuel or material);
b) The “measurement-based” approach, which involves measuring the
concentration of the greenhouse gases as well as the flow of the flue gas
for each “emission source” (stack).
Note, however, that during the introductory period until 31 July 2024 the
operator may apply other methods allowed for emissions monitoring in
their jurisdiction, if they lead to a similar emission coverage and accuracy.
These other methods may include default values made available and published
by the European Commission for the transitional period or any other default
values. However, they can be used in the condition that the reporting declarant
shall indicate and reference in the CBAM reports the methodology followed for
establishing such values. For PFC 7 emissions from primary aluminium
production a special methodology based on overvoltage measurements is to be
applied. For N2O emissions from nitric acid production, the measurement-based
method is compulsory. In all other cases, the operator may choose which method
best fits the situation of their installation.
o Indirect emissions: These are emissions occurring during the production of the
electricity that the installation of your supplier consumed, irrespective of whether
this electricity was produced within the installation or imported from outside.
You need to report the quantities of electricity consumed for each product
imported, and multiply it by the relevant emission factor of electricity. For the
latter factor, the following options exist:
a) If the electricity comes from the grid, you can use:
 The default emission factor provided by the European Commission
based on IEA 8 data, or
 Any other emission factor of the country of origin electricity grid based
on publicly available data representing either the average emission
factor or the CO2 emission factor.
b) If the operator also produces electricity within the installation (they are an
“auto-producer”). In this case the operator needs to monitor the emissions of
the power unit or CHP unit 9 in the same way as monitoring other direct
emissions of the installation, and use specific rules to calculate the
emission factor from the fuel mix and taking into account CHP heat
production, if applicable.
c) If the operator receives electricity from a specific installation under a “power
purchase agreement”. Provided this power unit monitors its emissions in line
with the same rules as applicable for auto-produced electricity and
6
The term “source stream” is used to cover both, fuels and other input or output materials that have an
influence on emissions.
7
Perfluorocarbons.
8
International Energy Agency.
9
CHP means Combined Heat and Power, also known as “Cogeneration”.
11
communicates that information to the operator and this is provided to you,
you may use the resulting actual emission factor for this electricity.
Detailed guidance is found in Section 6.1.4 of this document.
o Precursors (optional): The reporting of detailed data on precursors by the
operator to you, as the reporting declarant, is optional, as you do not need to
report this information separately in the CBAM report. However, it is necessary
for the emissions related to the precursor(s) to be included in the data that is
reported for the CBAM good, and therefore it is good practise for the precursor
data to be provided to facilitate the checking of the reported data.
The concept of embedded emissions includes the addition 10 of embedded
emissions of certain materials used in the production process, the so-called
precursors. Which precursors are relevant to each production process is listed
in section 3 of Annex II of the Implementing Regulation and is discussed in
Section 5 of this document for each affected sector.
b) If the precursor is produced within the same installation as the CBAM
good, the operator needs to include the precursor’s embedded emissions
when calculating the embedded emissions of the goods.
c) If the precursor is purchased from other installations, the producer of the
CBAM good needs to request data from the relevant suppliers of the
precursor in the same way as you are asking the for data on the goods that
are imported into the EU. The relevant information includes for each
precursor, separately for each installation of its production:
 Identification of the installation where it was produced;
 The specific 11 direct and indirect embedded emissions of the precursor;
 The production route, and additional parameters that the importer needs
to report when the final good is imported to the EU under the CBAM.
These additional parameters are listed in section 2 of Annex IV of the
Implementing Regulation and discussed in Section 5 of this document
for each affected sector.
 The reporting period applied by the supplier of the precursor.
 If applicable, information on a carbon price due by the supplier of the
precursor in the relevant jurisdiction (see point 5 below).
d) In both cases, i.e. for purchased or self-produced precursors, the operator
need to monitor the quantity of each precursor used during the reporting
period for each of their production processes.
The rules for monitoring precursor-related data are found in section E of Annex
III of the Implementing Regulation. More details are given in Section 6.1.5 of
this document.
o Finally, there are some additional qualifying parameters that you, as the EU
importer will need to report under the CBAM. These depend on the goods
10
Note the difference between precursors and normal input materials: For the determination of direct
emissions it is taken into account that the carbon atoms contained in a material may be oxidised to CO2
and emitted. However, for precursors, additionally the emissions which took place already earlier
(during their own production), i.e. the precursor’s embedded emissions, need to be added.
11
Specific (embedded) emissions means emissions related to one tonne of the material under discussion.
12
produced. For example, for cements imported, the total clinker content needs to
be reported, for mixed fertilizers, the contents of the different forms of nitrogen,
etc. The relevant parameters are listed in section 2 of Annex IV of the
Implementing Regulation. You need to ensure that operators provide the
necessary information on these parameters for their goods.
Step 3: Is a carbon price due in the jurisdiction where the goods or precursor goods
are produced? To ensure similar treatment between installations in the EU ETS and in
other countries, paying a carbon price in the country or sub-national region where a CBAM
good, and its precursors, are produced will allow for a reduction in the CBAM obligation
in the definitive period from 2026 onwards. There is also a need to report on this during
the transitional period of the CBAM (namely until the end of 2025). This reporting of
carbon prices during the transitional period is important to inform the European
Commission for consideration of any future improvements to the CBAM legislation.
Note that you need to collect information for each precursor purchased if a carbon price
applies in its country of origin. If the producer of the precursor does not provide the
required information, you must assume the carbon price due for the precursor to be zero.
The reporting rules of information regarding the carbon price due are found in Article 7 of
the Implementing Regulation. Detailed guidance is given in section 6.2.5 of this document.
Step 4: Understand the reporting period used by the operator. The default case is the
(European) calendar year. However, if the producing installation is situated in a country
with a different calendar, or where there are other reasonable arguments for a different
period, this may be used, too, if it covers at least three months. Suitable alternative periods
include in particular the reporting periods of a carbon pricing scheme or compulsory
emissions monitoring scheme in the country of your installation, or the fiscal year used.
The main reason for choosing such other periods is that there may be additional scrutiny
applied for those purposes, such as stock taking and financial auditing for annual financial
accounts, or third-party verification of emissions, which will give a higher level of
confidence in the quality of your data when also used for CBAM purposes. Further
guidance on reporting periods is given in Section 4.3.4.
Step 5: The operator must communicate the embedded emissions data to you, the EU
importer(s) who bear(s) the reporting obligation under the CBAM Regulation. As you
may purchase your goods from a multitude of suppliers, there may be a large number of
operators from whom you must request this information. In order to perform this
communication as efficiently as possible, the European Commission provides a common
template that can be used for this purpose.
While the use of this template is voluntary, it needs to be highlighted that the use of a
common template greatly simplifies the communication on both ends. Your suppliers
may be established in different countries and may speak different languages. The common
template ensures a common reporting format, so that the same type of information can
always be found in the same field in the template, and the meaning of each field will also
be clear.
At the end of each reporting period, the operator must compile the monitored data of the
whole reporting period, determine the attributed emissions of each production process,
and divide them by the corresponding “activity level” (i.e. the total tonnes of goods under
the related CBAM category produced within the reporting period) in order to get the
specific embedded emissions of the good. This is the main parameter you need to obtain
from the operator, plus the additional qualifying parameters mentioned under steps 2 and
3 above.
13
The template can be found on the European Commission’s dedicated website for the
CBAM. It has been designed based on the rules set out in Annex IV of the Implementing
Regulation on the content of the recommended communication from operators of
installations to reporting declarants. More guidance on compiling relevant information for
importers and using the template is given in Section 6.3 of this document and directly
within the template.
What happens after the transitional period.

From 2026, the definitive period of the CBAM will apply. That means that from 1
January 2026 onwards, importers will have to bear a “CBAM obligation” in the form of
certificates, which you purchase at the average price of EU ETS allowances, for every
CBAM good imported into the EU. There will be a phase-in with increasing coverage
of embedded emissions by the CBAM obligation from 2026. The full embedded
emissions will only be covered from 2034 onwards 12.
12
The detailed calculation formula will be developed and published by the European Commission at a
later stage.
14
4 THE CARBON BORDER ADJUSTMENT MECHANISM
4.1 Introduction to the CBAM
The Carbon Border Adjustment Mechanism (CBAM) is an environmental policy

instrument designed to support the EU climate ambitions of achieving a net reduction of
greenhouse gas (GHG) emissions of at least 55% by 2030 and of reaching climate
neutrality by 2050 at the latest.
The CBAM complements the EU Emission Trading System (EU ETS), which was recently
strengthened as part of the EU’s “Fit for 55” legislative package. Under the EU ETS,
operators of installations producing emission-intensive goods surrender emission
allowances for each tonne of CO2e emissions. Since an (increasing) amount of these
allowances are purchased in auctions or on the secondary market, these producers face a
‘carbon price’ 13 on their GHG emissions. However, producers in many non-EU countries
do not have such an obligation, and this competitive advantage puts European products at
risk of carbon leakage i.e. a relocation of production to outside of the EU.
In order to mitigate the risk of carbon leakage prior to the CBAM, the relevant industry
sectors have been receiving a part of their allowances free of charge (“free allocation”)
under the EU ETS. With the introduction of the CBAM, free allocation will gradually be
phased out as the CBAM is gradually phased in. Instead of alleviating the carbon costs for
EU producers, the CBAM ensures that importers of goods from non-EU countries bear
similar carbon costs for the “embedded emissions” of the imported goods. This general
guiding principle of both EU ETS and CBAM aims to incentivise emissions reductions on
an equivalent basis between EU producers and non-EU producers exporting to the EU.
The CBAM does not target countries but the embedded carbon emissions of products
imported into the EU for specific sectors that are within the scope of the EU ETS and the
most at risk of carbon leakage. These are: cement, iron and steel, aluminium, fertilizers,
hydrogen and electricity. It also includes some precursors and some downstream products
of the aforementioned sectors (hereinafter referred to as “CBAM goods”). For a complete
list of CBAM goods per sector see Section 5 of this document.
The CBAM will be introduced in phases as follows:
• Transitional period (1 October 2023 to 31 December 2025):

Designed as a “learning phase”, during which CBAM importers will report a set
of data, including emissions embedded in their goods, without paying a financial
adjustment for the embedded emissions. However, penalties may be imposed, for
example for failing to submit the required quarterly CBAM reports.
• Definitive period (starting on 1 January 2026):
o From 2026 to 2033, the embedded emissions for CBAM goods will be
gradually covered by the CBAM obligation, as free allocation under the
EU ETS is gradually phased out.
o From 2034, 100% of embedded emissions of the CBAM goods will be
covered by CBAM certificates and no free allocation will be given under
the EU ETS for these goods.
13
More precisely, a price for the CO2 or other equivalent greenhouse gas emissions.
15
The CBAM in the definitive period is designed to mirror the emission cost under the EU
ETS:
• EU operators will pay the CO2 price of their emissions and surrender allowances
(EUAs) under the EU ETS; and
• EU importers of CBAM goods into the EU will surrender CBAM certificates that
closely reflect the situation of the EU ETS, both in terms of MRV rules and of the
price of the certificates.
The CBAM is designed in compliance with World Trade Organization (WTO) rules and
other international obligations of the EU and applied equally to imports from all countries
outside the EU. 14
This document only deals with the requirements of the transitional period.
This period is meant for learning and setting up of the relevant MRV approaches outside
the EU, and of institutions and information technology systems within the EU.
4.2 Definitions and scope of emissions covered in the CBAM
The textbox below signposts the key sections in the Implementing Regulation defining
terms used for the CBAM.
Implementing Regulation references:
The CBAM Regulation (EU) 2023/956, Chapter I Article 3 Definitions and Annex IV Definitions
Annex II, Section 1 Definitions.
A list of abbreviations and definitions used is also provided in annexes in the back of this guidance document.
The following terms are frequently used in this guidance document:
• ‘tonne of CO2e’ means one metric tonne of carbon dioxide (‘CO2’), or an amount
of any other greenhouse gas listed in Annex I adjusted to the equivalent global
warming potential of CO2.
• ‘Direct emissions’ means emissions from the production processes of goods,
including emissions from the production of heating and cooling consumed during
the production processes, regardless of the location of the production of the
heating and cooling.
• ‘Indirect emissions’ means emissions from the production of electricity, which is
consumed during the production processes of goods, regardless of the location of
the production of the consumed electricity.
14
The only exception are goods from countries that either apply the EU ETS (currently Iceland, Norway
and Liechtenstein) or have an ETS fully linked with the EU ETS (currently Switzerland). Producers in
these countries therefore face the same carbon price as in the EU.
16
• ‘Embedded emissions’ means emissions released during the production of
goods, including the embedded emissions of relevant precursor materials
consumed in the production process.
• ‘Relevant precursor material’ means a simple or complex good which has
embedded emissions not equal to zero and which is identified as being within the
system boundaries for the calculation of embedded emissions of a complex good.
• ‘Simple goods’ means goods produced in a production process requiring
exclusively input materials and fuels having zero embedded emissions.
• ‘Complex goods’ means goods other than simple goods.
• ‘Specific embedded emissions’ means the embedded emissions of one tonne of
goods, expressed as tonnes of CO2e emissions per tonne of goods.
• ‘Specific embedded emissions’ means the embedded emissions of one tonne of
goods, expressed as tonnes of CO2e emissions per tonne of goods.
• ‘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 Table 1 of Section 2 of Annex II to the Implementing
Regulation, and its specified system boundaries regarding inputs, outputs and
corresponding emissions.
• ‘Aggregated goods category’ is implicitly defined in the Implementing Regulation
by listing the relevant aggregated goods categories and all the goods identified by
their CN codes in Table 1 of Section 2 of Annex II.
• ‘Production route’ means a specific technology used in a production process to
produce goods under an aggregated goods category. One production process
usually relates to one group of CBAM goods produced (the ‘aggregated goods
categories’). However, in some case more than one production route exists for
producing these goods.
4.3 Transitional period
A summary of key elements of the transitional period is presented in Table 4-1.
Table 4-1 Transitional period – key points
Duration 1 October 2023 to 31 December 2025.

MRV rules Implementing Regulation (EU) 2023/1773
Reporting of indirect Required for all CBAM goods.
emissions
Default values for Global values
reporting of (except electricity).
embedded emissions May be used for precursors of complex goods contributing up
to 20% of the total for the complex good.
Must be used for imports of electricity and for indirect
emissions, unless certain criteria are met.
17
Flexibility regarding The use of rules from other (non-EU) carbon pricing or
MRV rules reporting schemes are allowed for operators of installations
until the end of 2024, if they cover the same emissions and
provide similar accuracy.
Importers may use other (estimation) methods until 31 July
2024.
Frequency of Quarterly (importers).
reporting
Verification of Not required.
reported data Operators and importers should aim to report as accurately
and completely as possible.
If verification has been undertaken this should be noted in the
submission.
Surrender of CBAM Not required.
certificates
4.3.1 Key reporting roles and responsibilities
The “reporting declarant” 15 is the entity which is responsible for the reporting of
embedded emissions of imported goods. In principle, the reporting declarant is the
“Importer”. However, in practice there are different options depending on the person
lodging the customs declaration. Where different actors are involved in the importation
process, it is important to remember that every tonne of imported good is the responsibility
of exactly one reporting declarant, i.e. that it is neither reported twice nor omitted from
reporting.
In line with the options provided under the Union Customs Code (UCC 16), the reporting
declarant can be either 17:
• The importer who lodges a customs declaration for release for free circulation
of goods in its own name and on its own behalf;
• The person, holding an authorisation to lodge a customs declaration referred to
in Article 182(1) of the UCC, who declares the importation of goods; or
• The indirect customs representative, where the customs declaration is lodged
by the indirect customs representative appointed in accordance with Article 18 of
the UCC, when the importer is established outside the Union or where the indirect
customs representative has agreed to the reporting obligations in accordance with
Article 32 of the CBAM Regulation.
The reporting declarant must provide a ‘CBAM report’ on a quarterly basis 18, to the
European Commission via the CBAM Transitional Registry, at the latest by the end of
15
The Implementing Regulation uses this term in order to cover both situations, either where an importer
or its indirect customs representative are responsible for the CBAM reporting.
16
Regulation (EU) No 952/2013, consolidated version: http://data.europa.eu/eli/reg/2013/952/2022-12-12
17
Article 2(1) of the Implementing Regulation.
18
Article 35 of the CBAM Regulation
18
the month following the end of the quarter. This is to report the information listed in
section 6.3.2 on the goods imported into the EU during that quarter. Note the specific
requirements, including on the date of importation, in case of the so-called “inward
processing” customs procedure (see section 4.3.6).
Due to the administrative requirements of the CBAM, it is expected that many importers
may make use of customs representatives, i.e. importers may delegate their obligations.
Where the importer is not established in an EU Member State, the CBAM reporting
obligations apply to the indirect customs representative. If an importer established in the
EU appoints an indirect customs representative, the reporting obligations can be fulfilled
by the indirect customs representative.
The operator of an installation producing CBAM goods outside the EU is the second key
role for the functioning of the CBAM. Installation operators are the persons who have
direct access to information on the emissions of their installations. They are therefore
responsible for monitoring and reporting the embedded emissions of goods they have
produced and are exporting to the EU.
Third-party verifiers will play an important role in the definitive period. However, during
the transitional period, verification is a fully voluntary measure which operators of
installations may choose as a means to improve their data quality, and to prepare for the
requirements of the definitive period.
Furthermore, the competent authority in the EU Member State where the reporting
declarant is established plays an important role. It is in charge of enforcing the certain
provisions of the CBAM Regulation, such as reviewing the CBAM reports to ensure that
reporting declarants submit complete and correct quarterly CBAM reports, and to impose
penalties in line with the Implementing Regulation, if necessary.
The European Commission (in this document also referred to as “the Commission”) is
responsible for running the CBAM Transitional Registry, assessing the overall
implementation of the CBAM during the transitional period by checking the information
contained in the quarterly CBAM reports, for further developing the legislation with a view
to the definitive period, and for co-ordinating the competent authorities in the EU Member
States. Furthermore, the European Commission provides a dedicated website for the
CBAM, with further guidance documents, templates for reporting, training material, and
the portal to the CBAM Transitional Registry (which will be further updated to become
the CBAM Registry in the definitive period).
4.3.2 What needs to be monitored by operators
The first element is the monitoring of direct emissions of the installation. Whenever an
installation produces several different products, the emissions must also be appropriately
attributed to the individual products.
Operators must also monitor and report to the reporting declarant(s) the quantities of
specific input materials which themselves have embedded emissions (the so-called
“relevant precursors”, which are themselves CBAM goods) used in the manufacturing
process, and determine the embedded emissions of these precursor materials. Where
operators purchase precursors to produce other CBAM goods, they need to obtain data on
the embedded emissions from the supplier of these precursors.
19
Indirect emissions released from the generation of the electricity consumed during the
production of all CBAM goods must be monitored for the purposes of the CBAM 19 and
attributed to the goods produced. Again, emissions embedded in precursors must be
included, where relevant.
Note that only direct emissions are relevant for electricity imported into the EU as a good
in its own right. The treatment of electricity as a CBAM good is discussed further in the
guidance document for operators.
Explanations of how to determine these embedded emissions and to define system

boundaries are elaborated upon in the guidance document for operators. Relevant
precursors are identified for each sector in the following Section 5.
Finally, operators must communicate to the importer(s) the carbon price due for the
production of the good within its own jurisdiction, if any. This includes the carbon price
per tonne CO2e, and the amount of free allocation or any other financial support,
compensation or rebate received per tonne of the product relevant for the CBAM. Notably,
in case of complex goods, the carbon costs due by the producers of precursor materials
should also be taken into account.
4.3.3 What needs to be reported by reporting declarants
During the transitional period, importers need to report on a quarterly basis the
embedded emissions in goods imported during that quarter of a calendar year,
detailing direct and indirect emissions as well as any carbon price effectively due abroad.
Since the importer only uses emissions data generated elsewhere, the main task is to
ensure the completeness of the imports list and of the other relevant factors to be
reported in the CBAM report.
The following information must be reported by importers in the CBAM report:
• The total quantity of each type of goods, expressed in megawatt hours (MWh)
for electricity and in tonnes for other goods, specified per installation producing
the goods in the country of origin;
• The actual total embedded emissions, expressed in tonnes of CO2e emissions per
MWh of electricity or for other goods in tonnes of CO2e emissions per tonne of
each type of goods;
• The total indirect emissions, including amount of electricity consumed and the
applicable emissions factor;
• The carbon price due in a country of origin for the embedded emissions in
the imported goods, taking into account relevant rebates or other forms of
compensation.
In order to obtain this information, it is imperative to have a clear procedures in place for
monitoring imports. Suggested best practices include:
19
During the transitional period, indirect emissions of all CBAM goods are to be monitored and reported,
including the embedded indirect emissions of precursors. However, in the definitive period, indirect
emissions will be included only for certain products (the goods included in Annex II to the CBAM
Regulation).
20
• If the CN code of the good being imported falls within the list of goods given by
Annex I to the CBAM Regulation, the reporting obligation under the CBAM has
to be triggered. The most efficient way for importers to handle the CBAM might
be to install a tool which generates a list of all imported goods falling under the
CBAM. This could, for example, be carried out automatically by book-keeping
software.
• The importer could also make the disclosure of information a dedicated clause in
the purchase contract with the producer of the goods imported.
If the operator uses the simple spreadsheet provided to prepare their CBAM declaration,
then it will only require limited efforts by the reporting declarant to complete the report in
the CBAM Transitional Registry, provided the list of imported goods is kept up-to-date,
and the embedded emissions per tonne of product are known. However, the use of this
spreadsheet tool is not mandatory and therefore importers may receive the required data
from operators in other formats. It is therefore important that reporting declarants are aware
of the parameters to be reported to ensure the necessary data are received from operators.
The contents of the CBAM report is set out in Annex I of the Implementing Regulation.
4.3.4 Reporting periods for operators and importers
The reporting period is the reference period for determining embedded emissions.
operators and importers have different reporting periods.
Installation operators
For operators, the default reporting period is twelve months to allow them to collect
representative data that reflects an installation’s annual operations.
The twelve-month reporting period may be either a:
• Calendar year – which is the default option for reporting; or alternatively a

• Fiscal year – if this can be justified on the basis that the data for a fiscal reporting
year is more accurate, or to avoid incurring unreasonable cost; for example,
where the financial year end coincides with an annual stock take of fuels and
materials.
A period of twelve months is considered representative as this reflects seasonal variations
in an installation’s operations, as well as any periods of disruption to the process resulting
from planned annual shutdowns (e.g. for maintenance) and start-ups. A full year also helps
to mitigate any data gaps e.g. by taking meter reads on either side of any missing periodic
data points.
However, operators may also choose an alternative reporting period, of a least three
months, if the installation participates in an eligible MRV system and the reporting period
coincides with the requirements of that MRV system. For example:
• A mandatory carbon pricing scheme (an emission trading system or carbon tax,
levy or fee) or GHG reporting scheme with a compliance obligation. In this case
that scheme’s reporting period may be used, if it covers at least three months; or
• Monitoring and reporting for the purpose of another monitoring scheme (e.g. a
GHG emission reduction project, which includes verification by an accredited
21
verifier. In this case the reporting period of the applicable MRV rules may be
used if it is at least three months.
In all the above cases, the direct and indirect embedded emissions of goods should be
calculated as the average of the reporting period chosen.
In order to allow representative data to be reported from the start of the transitional period,
operators should aim to share a full year of data for 2023 in January 2024, with importers,
for the first quarterly report. In order to do this, operators should:
• Collect emissions data and activity data from the start of the transitional period,
for as much of 2023 as is available. For the period before actual emissions
monitoring starts 20, operators will have to make estimates based on best available
data (e.g. by using production protocols, backward calculation based on known
correlations between known data and the relevant emissions, etc.).
• Start to collect data for the last quarter of 2023 in preparation for reporting a full
year of data to importers, if possible, as early as possible at the start of January
2024.
In light of the above, operators should therefore start preparing their monitoring
methodology as soon as possible and aim to start actual monitoring as soon as possible
after 1 October 2023. They should share their embedded emissions data with importers as
soon as they are available after the end of each quarter.
Importers
During the transitional period, the reporting period for importers (“reporting declarants”)
is quarterly, with reports due within one month.
• The first quarterly report is for the period October to December 2023, with the
report due to be submitted on the CBAM Transitional Registry by 31 January
2024.
• The last quarterly report will be for the period October to December 2025, with
the report due to submitted on the CBAM Transitional Registry by 31 January
2026.
The quarterly report should summarise the embedded emissions in goods imported during
the previous quarter of the calendar year, splitting out direct and indirect emissions, as well
as any carbon price due abroad. For deciding at what date a good was imported, the
“release to the market” (i.e. the clearance by the customs authorities) is relevant. This is
important in particular for goods put under the “inward processing” procedure (see
section 4.3.6).
As operators and importers have different reporting timelines, importers will need to use
the latest embedded emissions data communicated to them by installation operators, for
their quarterly CBAM reports. For example, where an operator has a calendar year as their
reporting period, an importer completing a quarterly CBAM report for any of Q1 to Q4 of
2025 would need to use the specific embedded emissions information for the good for
calendar year 2024 for reporting purposes, as communicated to them by the operator. I.e.
if the good was manufactured by an operator in December 2024 and was imported into the
EU by an importer in January 2025, the importer’s Q1 CBAM report would use the specific
20
This will be the most frequent case, except where an eligible MRV system is already in place.
22
embedded emissions for that good for calendar year 2024. If the 2024 data are not yet
available by the end of January 2025, data on specific embedded emissions from 2023
could be used for the Q1 CBAM report.
A difference would be where an operator has a compliance obligation under an eligible

MRV system and the reporting period is shorter than a calendar year, but at least three
months. For example, if the reporting period is three months, the importer may use the
operator’s Q1 data in their Q2 CBAM report, and so on.
Note that a CBAM report which has already been submitted may still be corrected 21 until
two months after the end of the reporting quarter. This may be the case, for example, when
more accurate data on embedded emissions becomes available to the importer after the
reporting deadline. Acknowledging the difficulty to set up MRV systems in time, the
Implementing Regulation allows a longer period for corrections for the first two quarterly
reports, which is until the deadline for the third quarterly report. This means that the
reports due by 31 January and 30 April 2024 may be subsequently corrected until 31 July
2024.
4.3.5 Governance of the CBAM
Figure 4-1: Overview of the reporting responsibilities in the transitional period of the CBAM
Non-EU countries Installations in various countries
Import of
Verification goods
optional
Competent Authority 1
Member States Request data
on embedded
6 emissions 4
Information
exchange
Importer
 Customs
declaration
European 2
Commission Quarterly reports on (reporting
5 embedded emissions
declarant)
👮 Customs
CBAM Transitional
Registry
authority
3 Information of import
Graphic by
For explanation of the numbers (relating to the workflow), please see main text below.
As shown schematically in Figure 4-1, the governance system and workflows in the
transitional period of the CBAM follow the sequential steps below (paragraph numbering
follows the red numbers in the figure):
1. The importer (reporting declarant) receives CBAM goods from various

installations, possibly from different countries outside the EU.
21
Article 9 of the Implementing Regulation.
23
2. For each import, the importer lodges the usual customs declaration. The customs
authority of the relevant EU Member State checks and clears the import, as usual.
3. The customs authority (or the IT system used) informs the European Commission
(using the CBAM Transitional Registry) of this import. This information can then
be used to check the completeness and accuracy of quarterly CBAM reports.
4. The reporting declarant requests the relevant data on specific embedded emissions
of the imported CBAM goods from the operators (in practice, this may involve
intermediary traders, who would have to forward the request to the operator of the
installation which produced the CBAM goods). The latter reply by sending the
requested data, if possible using the template provided for this purpose by the
Commission. The data may be voluntarily verified by a third-party verifier.
5. The reporting declarant is then able to submit the quarterly CBAM report to the
CBAM Transitional Registry.
6. An information exchange between the Commission and the competent authorities
in the EU Member States takes place. The Commission informs (based on the
customs data), which reporting declarants are expected to submit CBAM reports.
Furthermore, the Commission can perform spot checks of actual reports and check
their completeness with regards to the customs data. Where irregularities are
identified, the Commission informs the competent authority of this. The competent
authority will then follow up, usually by getting in contact with the importer and
requesting rectification of the irregularity, or submission of the missing CBAM
report. If the reporting declarant does not correct the mistakes, the competent
authority can ultimately impose a (financial) penalty.
7. (Not shown in the figure and not required by legislation, but in the own interest of
the importer): to avoid similar problems in the future, the importer who received a
penalty should inform the operator of the problem(s) identified by the Commission
or the competent authority in order to address the issue(s) for future submissions.
4.3.6 Inward processing
The Union Customs Code defines several special procedures. “Inward processing” 22
means that a good is imported into the EU for processing with suspension of import duties
and VAT. After the processing operations, the processed products or the original imported
goods can then be either re-exported or released for free circulation in the EU. The latter
would imply the obligation to pay import duty and taxes, as well as the application of
commercial policy measures.
This principle is extended to the CBAM, i.e. in the case of re-export, no obligation for
reporting under the CBAM arises for goods placed under inward processing. However, if
the CBAM good is released to the EU market after inward processing, either as the original
good or modified, a CBAM reporting obligation arises.
For goods actually imported after having been put under inward processing, the period
under which they must be included in the CBAM report is determined by the date of release
for free circulation within the EU. For this reason, in some cases goods may have to be
22
See: https://taxation-customs.ec.europa.eu/customs-4/customs-procedures-import-and-export-0/what-
importation/inward-processing_en
24
reported under the CBAM although they were put under inward processing before 1
October 2023.
Article 6 of the Implementing Regulation provides some special reporting requirements

for goods released for free circulation after inward processing for the purposes of the
quarterly CBAM reports:
• If the good was not modified during the inward processing, the quantities of the
CBAM good released and the embedded emissions of those quantities are to be
reported; the values are the same as for the good placed under inward processing.
The report shall also include the country of origin and the installations where the
goods were produced, if those are known;
• If the good was modified, and the product of the inward processing no longer
qualifies as a CBAM good, then the quantities of the original good and embedded
emissions of those original quantities are still to be reported. The report shall also
include the country of origin and the installations where the goods were produced,
if those are known;
• If the good was modified, and the product of the inward processing is a CBAM
good, then the quantities and the embedded emissions of the good released to the
market are to be reported. If the inward processing takes place in an EU ETS
installation, the carbon price due is also to be reported. The report shall also
include the country of origin and the installations where the goods were produced,
if those are known;
• Where the origin of the good used for inward processing cannot be defined, the
embedded emissions shall be calculated on the basis of the weighted average
embedded emissions of the totality of the goods placed under the inward
processing procedure for the same aggregated good category.
25
5 CBAM GOODS AND PRODUCTION ROUTES
5.1 Foreword to sector specific sections
The following sections provide an overview of the different production routes for the goods
listed in Annex I to the CBAM Regulation for the cement, hydrogen, fertilizers, iron and
steel, and aluminium sectors. This section deals with the specification of products covered
by the CBAM and the relevant production routes. This is intended to help you, as the
reporting declarant, to identify the CBAM goods imported and to understand the basis for
the specific embedded emissions for these goods that are reported to you by the producer.
Diagrams used in the following sections.

For the system boundary graphics presented in the sections below, the following
conventions are applied:
 Production processes (for which monitoring of the direct emissions would take
place) are shown as rectangles; Materials are shown in boxes with rounded
corners.
 Optional processes (e.g. CCS/CCU) are shown in blue boxes. In particular,
CCS/CCU would not be taken into account for developing default values, but
where you, as an operator, uses them, the related emissions or emission savings
should be taken into account for determining actual embedded emissions.
 Materials which are considered to have no embedded emissions are shown in red
boxes, materials with embedded emissions (relevant precursor materials and final
products, i.e. goods under the CBAM) in green boxes. Simple goods are shown in
normal font, complex goods in bold font.
 Input materials are presented without trying to be complete. This means that the
focus is on materials which are relevant for demonstrating the differences between
different production routes. As a consequence, less important input materials and
in particular fuels are usually omitted in order to keep graphs simple.
 Note: CCS/CCU processes are indicated in the following Figure 5-1 for the
cement value chain as an example. For keeping graphs reasonably simple, this is
not shown in other sectors, but equally applicable there.
Electricity as input is shown only in cases where it is the main “precursor” of the process
(i.e. in particular for electric arc furnaces and electrolysis processes).
5.2 Identifying CBAM goods
This section explains how goods covered by the CBAM are defined and identified in the
Regulation. The textbox below signposts the key sections for the definition and reporting
of CBAM goods, relevant for the CBAM transitional period.
Annex II, Section 2, Table 1 Mapping of CN codes to Aggregated goods categories.
Annex III, Section F Rules for attributing emissions of an installation to goods.
26
5.2.1 Product specifications
The Combined Nomenclature (CN) 23,24 classification system defines the essential
characteristics of goods and is used to identify those sector goods in scope for the CBAM.
The CN ‘product specification’ classification system comprises two parts, firstly a

numerical 4, 6 or 8-digit numbering system, reflecting different levels of product
disaggregation, and secondly a short text description of each product category giving its
essential characteristics. The first 6 digits are identical to the Harmonised System (HS)
classification used in international trade and the remaining 2 digits are EU-specific
additions.
Both parts of the goods’ product specification are given in Annex I to the CBAM
Regulation, but elsewhere in the text this may also be abridged to the numerical code only,
for ease of reference.
5.2.2 Identifying goods in scope for the CBAM Regulation
You, as the reporting declarant, should first establish which imported goods fall under the
scope of the CBAM. You should check and compare the full range of goods imported
against the product specifications given in Annex I to the CBAM Regulation to establish
which goods are within the scope of the CBAM.
The following sections provide further information to assist you in this process by listing
the relevant CBAM goods for each sector. Relevant precursors are also identified to
facilitate your checks of the data that is reported to you by the producers of goods you are
importing into the EU. If the operator reports information for precursors that are not
identified against the CBAM goods as shown in this guidance document, then it is
recommended you seek clarification from the operator on whether this has been reported
correctly 25.
A more detailed explanation of the relevant production processes and system boundaries
of the goods is presented in the guidance documents for operators of non-EU installations
producing CBAM goods.
Boundaries for production processes producing goods
In order to determine the embedded greenhouse gas emissions of CBAM goods, the
boundaries of the production processes producing these goods must be defined by the
operator 26. To do this the operator must identify what material and energy flows that can
have an impact on emissions form part of the CBAM production process. Once the system
23
Council Regulation (EEC) No 2658/87 of 23 July 1987 on the tariff and statistical nomenclature and on
the Common Customs Tariff (OJ L 256, 7.9.1987, p. 1).
24
For further information on the CN definitions for goods see the Eurostat RAMON database for 2022 at:
https://ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm?TargetUrl=LST_NOM_DTL&StrNom=
CN_2022
25
Note that it is possible for the same goods category to be applicable to both the good produced and for
the precursor used to produce that good. This is relevant for iron and steel, aluminium and fertilizer
sector goods.
26
Operator’ means any person who operates or controls an installation in a third country
27
boundaries for the production process have been defined then the emissions associated
with the production of the good can be monitored.
It is also important to clarify what upstream processes (e.g. production of precursor goods)
and downstream activities (e.g. rolling or casting, cleaning and coating of steel products)
take place on the same installation. This is because different monitoring rules may apply
to these activities and separate production process may need to be defined.
Where an installation produces more than one category of aggregated CBAM good the
operator should split the installation into separate production processes so that the
emissions from each production process are monitored separately. Ultimately, the
embedded emissions attributed to the goods produced by the different production processes
should still sum to 100% of the relevant total emissions of the installation.
5.3 Cement sector
The textbox below signposts sector-specific sections in the Implementing Regulation,

relevant for the CBAM transitional period.

• Annex II, Section 2, Table 1 Mapping of CN codes to aggregated goods
categories.
• Annex II, Section 3 Production routes, system boundaries, and relevant
precursors, as specified in sub-sections: 3.2 – Calcined Clay, 3.3 – Cement
clinker, 3.4 – Cement, 3.5 – Aluminous cement.
5.3.1 Unit of production and embedded emissions for industry sector
The quantity of declared cement goods imported into the EU should be expressed in metric
tonnes. You, as a reporting declarant, should report the quantity of CBAM good(s)
imported into the EU.
Industrial sector Cement

Production unit of goods Tonnes (metric), reported separately for each type
of CBAM good produced, by the installation or
production process in the country of origin.
Associated activities Producing cement clinkers and calcined clays,
grinding and blending cement clinker to produce
cement.
Relevant greenhouse gas Carbon dioxide (CO2)
emissions
Direct Emissions Tonnes (metric) of CO2e
Indirect Emissions Quantity of electricity consumed (MWh), source
and emissions factor used to calculate the indirect
emissions in tonnes (metric) of CO2 or CO2e.
28
Industrial sector Cement
To be reported separately during transitional
period.
Unit for embedded emissions Tonnes CO2e emissions per tonne of good,
reported separately for each type of CBAM good,
by the installation or production process in the
country of origin.
The cement sector has to account for both direct emissions and indirect emissions in the
transitional period. Indirect emissions are to be reported separately. Emissions should be
reported in metric tonnes of CO2 equivalent (tCO2e) emissions, per tonne of good output.
This figure should be calculated for the specific installation or production process in the
country of origin.
The following sections identify elements of the production process that should be included
for the purposes of monitoring and reporting.
5.3.2 Definition and explanation of goods covered
The table below lists the relevant goods in scope for the CBAM transitional period in the
cement industry sector. The aggregated goods category in the left hand column defines
groups for which joint ‘production processes’ are to be defined for the purpose of
monitoring.
Table 5-1: CBAM goods in the cement sector
Aggregated goods category CN Code Description

Calcined clay 2507 00 80 Other kaolinic clays
Cement clinker 2523 10 00 Cement clinkers 27
Cement 2523 21 00 White Portland cement,
whether or not artificially
coloured
2523 29 00
Other Portland cement
2523 90 00
Other hydraulic cements
Aluminous cement 2523 30 00 Aluminous cement 28
Source: The CBAM Regulation, Annex I; Implementing Regulation, Annex II.
The aggregated goods categories listed in the table above include both finished cement
goods and precursor goods (intermediate products) that are consumed in the production of
cement.
27
No distinction is made between different types of clinker, i.e. grey and white cement clinker are the same
for the purposes of the CBAM.
28
Also referred to as ‘Calcium Aluminate Cement’.
29
Only input materials listed as relevant precursors to the system boundaries of the
production process as specified in the Implementing Regulation are to be considered. Table
5-2 below lists the precursors by aggregated goods category and production route.
Table 5-2: Aggregated goods categories, their production routes and relevant precursors
Aggregated Goods Category Relevant precursors

Production route
Calcined clay None
Cement clinker None
Cement Cement clinker; calcined clay (if used in the
process).
Aluminous cement None
Precursor goods of relevance are ‘cement clinker 29’ (CN code 2523 10 00), which includes
both white clinker (used to make white cement) and grey clinker, and ‘calcined clay’ (CN
code 2507 00 80), which is a clinker substitute and may be used to modify the properties
of the cement produced.
These precursors are defined as simple goods, as the raw material constituents and fuels
(both fossil fuels and any alternative fuels) used in their manufacture are themselves
considered to have zero embedded emissions.
The finished cement goods listed in Table 5-1 comprise both white Portland cement, grey
Portland cement, other hydraulic cements and aluminous cement. These goods are defined
as complex goods (with the exception of aluminous cement) as they include the embedded
emissions from precursor goods.
Other constituents used in cement manufacture, in particular granulated blast furnace slag,
fly ash and natural pozzolana that are used in the manufacture of other hydraulic cement
goods (including blended or ‘composite’ cements) are not considered to have any
embedded emissions and are not in scope for the CBAM.
Cement sector goods are produced by a number of different process routes, outlined below.
5.3.3 Definition and explanation of relevant production processes and routes
The system boundaries for precursors and cement goods are distinct and may, under
certain conditions, be added together to include all processes directly or indirectly linked
29
No distinction is made between grey and white clinker, the operator should apply the relevant embodied
emissions of the relevant clinker precursor used.
30
to the production processes for these goods, including input activities to the process and
output activities from the process.
5.3.3.1 Calcined clay production process
Calcined clay may be used as a clinker substitute. Kaolinic clay that is calcined
(metakaolin) can be added to cement in place of clinker in varying proportions in order to
modify the properties of the cement mixture.
Note that the CN code for calcined clay (CN code 2507 00 80) includes other clays too,
which are not calcined and so are not subject to the CBAM; in this case the quantities of
non-calcined clay imported are still reported, but with zero embedded emissions and
without monitoring requirements for the producer.
There are no relevant precursors for calcined clay.
5.3.3.2 Cement clinker production process

Cement clinker is produced in clinker plants (kilns) by the thermal decomposition of
calcium carbonate to form calcium oxide, followed by the clinkering process in which the
calcium oxide reacts at high temperatures with silica, alumina and ferrous oxide to form a
clinker. Grey and white clinkers may be produced depending on the temperature of the
process and purity of raw materials.
There are no relevant precursors for cement clinker.
5.3.3.3 Cement production process

Cement (apart from aluminous cement) is defined as a complex good as it is produced from
relevant precursor cement clinker and possibly calcined clay. Cement clinker is ground
and blended with certain other constituents to produce the finished cement product.
Depending on the mix of different constituents this may be Portland cement, blended
cement (containing a mix of Portland cement and other hydraulic constituents), or other
hydraulic cements.
The following Figure 5-1 shows how the cement clinker and cement production processes
relate to each other.
31
Figure 5-1: System boundaries of cement clinker and cement production processes.
Cement clinker and cement production processes
Fuels and Limestone, clays, Alternative raw

alternative fuels etc materials
Calcined lime, Clinker CO2

dolime, magnesia production Emissions
CCS / CCU
processes
Clinker
System boundaries:
embedded emissions of clinker
Clinker
Gypsum Other constituents
Cement CO2
Calcined clays
grinding Emissions
System boundaries:
(Portland)
Cement embedded emissions
of (Portland) cement
Direct emissions of the clinker production process result from the combustion of fuels, and
from raw materials used in the process such as limestone. Direct emissions may also result
from fuels used for drying materials used to make the final cement product. Indirect
emissions result from electricity consumed by the processes.
5.3.3.4 Aluminous cement production process

Aluminous cement is regarded as a simple good as it is produced directly from aluminous
clinker by a continuous production process, and is ground without the addition of further
additives. Any emissions associated with the production of aluminous cement constituents
such as alumina (from bauxite) are deemed to be out of scope for the CBAM.
There are no relevant precursors for aluminous cement.
32
Figure 5-2: System boundaries of the aluminous cement production process
Aluminous cement production process
Direct emissions result from the combustion of fossil fuels and alternative fuels and from
raw materials such as limestone. Indirect emissions result from electricity consumed by
the process.
5.3.4 Additional reporting parameters
The following table lists the additional information that should be provided by the operator,
along with data on embedded emissions, in their emissions data communication to you the
importer.
Table 5-3: Additional cement sector parameters requested in the CBAM report
Aggregated goods Reporting parameter

category
Calcined clay 30 – Whether or not the clay is calcined.
Cement clinker – None.
Cement – Clinker content of cement expressed as percentage.
Aluminous cement – None.
These additional parameters depend on the goods produced. For example, for cements
imported, the total clinker content needs to be reported.
30
Note that clays falling under CN code 2507 00 80 that are not calcined, are assigned embedded emissions
of zero. They are still to be reported, but no additional information from the producer of the clay needs
to be obtained.
33
You will need to report the additional parameters in your CBAM Report when the final
good is imported to the EU under the CBAM.
Note that clays falling under CN code 2507 00 80 that are not calcined (that are assigned
embedded emissions of zero) still to be reported, but no additional information from the
producer of the clay needs to be obtained.
5.4 Chemicals sector – Hydrogen


categories.
precursors, as specified in sub-section: 3.6 – Hydrogen
5.4.1 Unit of production and embedded emissions
The quantity of hydrogen imported into the EU should be expressed in metric tonnes (as
pure hydrogen). As a reporting declarant, you should record the quantity of hydrogen
imported into the EU.
Industrial sector Chemicals – Hydrogen

Production unit of goods Tonnes (metric) pure hydrogen, reported
separately by installation or production process
in the country of origin
Associated activities Producing hydrogen by steam reforming or
partial oxidation of hydrocarbons, water
electrolysis, Chlor-Alkali electrolysis or
production of sodium chlorate.
Relevant greenhouse gases Carbon dioxide (CO2)
Indirect Emissions Quantity of electricity consumed (MWh),
source and emissions factor used to calculate
the indirect emissions in Tonnes (metric) of
CO2 or CO2e.
period.
Unit for embedded emissions Tonnes CO2e emissions per tonne of good,
reported separately for each type of good, by
installation in the country of origin
34
The hydrogen sector has to account for both direct emissions and indirect emissions in the
transitional period. Indirect emissions are to be reported separately 31. Emissions should be
reported in metric tonnes CO2 equivalent (tCO2e) emissions per tonne of output. This
figure should be calculated for the specific installation or production process in your
country of origin.
5.4.2 Definition and explanation of sector CBAM goods covered
hydrogen industry sector. The aggregated goods category in the left hand column defines
monitoring.
Table 5-4: CBAM goods in the chemicals sector – hydrogen
Aggregated goods Product CN Code Description

category
Hydrogen 2804 10 000 Hydrogen
Hydrogen is defined as simple good as the raw materials and fuels used in its manufacture
are considered to have zero embedded emissions.
There are no relevant precursors for hydrogen. However, hydrogen may itself be a
relevant precursor for other processes, where it is separately produced for use as a chemical
feedstock to produce ammonia, or to produce pig iron or direct reduced iron (DRI).
The production of hydrogen is by a number of different process routes, outlined below.
Hydrogen can be produced from various feedstocks including plastic wastes, but currently
it is derived mostly from fossil fuels. Hydrogen production units are typically integrated
into larger industrial processes e.g. as for an installation producing ammonia.
The following diagram illustrates the variety of different routes by which hydrogen may
be produced.
31
Note that for this sector indirect emissions are only reported during the transitional period (and not
during the definitive period).
35
Figure 5-3: System boundaries of different production routes for hydrogen – overview
Production routes for hydrogen – overview
The system boundaries for direct emissions monitoring for hydrogen includes all processes
directly or indirectly linked to hydrogen production, and all fuels used in the production of
hydrogen.
Note that other production routes for hydrogen are possible, e.g. hydrogen produced as a
by-product from the production of ethylene, but that only the production of pure hydrogen
or mixtures of hydrogen with nitrogen usable in ammonia production shall be considered.
Not covered are the production of synthesis gas or of hydrogen within refineries or organic
chemical installations, where the hydrogen is exclusively used within those plants, and not
used for the production of goods under the CBAM Regulation.
5.4.3.1 Hydrogen - Steam reforming production route

The natural gas feedstock for this process is converted to carbon dioxide and hydrogen
through primary and secondary steam reformation. The overall reaction is highly
endothermic and process heat is supplied by the combustion of natural gas or other gaseous
fuel. Carbon monoxide produced is almost all converted to carbon dioxide by the process.
The stream of carbon dioxide produced by the steam reforming process is very pure and is
separated and captured for further use, e.g. for urea production. A variation on this process
is steam reformation with carbon capture and sequestration (CCS).
5.4.3.2 Hydrogen - Partial oxidation of hydrocarbons (gasification) production route

Hydrogen is produced by the partial oxidation (gasification) of hydrocarbons, typically
from heavy feedstocks such as residual heavy oils or coal and even waste plastics. Carbon
monoxide produced by the process is almost all converted to carbon dioxide.
Direct emissions for the steam reforming and partial oxidation production routes result
from fuel combustion and from the process materials used for flue gas cleaning. The stream
of carbon dioxide produced from the process is of high purity and is separated and captured
for further use. Indirect emissions result from electricity consumed by the process.
36
5.4.3.3 Hydrogen - Electrolysis of water production route
Water electrolysis is a standalone, non-integrated production process that produces a very
pure stream of hydrogen gas. Direct emissions of carbon dioxide from this process are
minimal. Indirect emissions result from electricity consumed by the process. Hydrogen
produced by renewable electricity may become relevant in the future.
5.4.3.4 Hydrogen - Chlor-alkali electrolysis (and production of chlorates) production

route
Hydrogen is produced as a by-product of the electrolysis of brine, alongside the
simultaneous production of chlorine and sodium hydroxide. There are three basic chlor-
alkali process techniques: mercury cell, diaphragm cell and the membrane cell. All three
cell techniques produce hydrogen, which is formed at the cell cathode and which leaves
the cell at very high purity. The hydrogen gas produced is cooled, dried and purified to
remove water vapour and other impurities including in some cases oxygen, and is then
compressed and stored or exported off site.
Direct emissions from the Chlor-Alkali production route result from fuel use directly or
indirectly linked to the production process and from the process materials used for flue gas
cleaning. Indirect emissions result from electricity consumed by the process.
importer.
Table 5-5: Additional chemicals sector parameters covered in the CBAM report
Aggregated good Reporting requirement in the quarterly report

category
Hydrogen – None
There is no additional reporting required for hydrogen produced.
5.5 Fertilizers sector


• Annex II Section 2, Table 1 Mapping of CN codes to aggregated goods
categories.
37
precursors, as specified in sub-sections: 3.7 – Ammonia; 3.8 – Nitric acid; 3.9
– Urea; 3.10 – Mixed fertilizers.
The quantity of declared nitrogen containing fertilizer sector goods imported into the EU
should be expressed in metric tonnes. As a reporting declarant, you should report the
quantity of CBAM goods imported into the EU.
Industrial sector Fertilizers

Production unit of goods Tonnes (metric) 32, reported separately for each
type of sector goods, by installation or
production process in the country of origin
Associated activities Producing chemical precursors for nitrogenous
fertilizer production, producing nitrogenous
fertilizers by physical mixing or chemical
reaction, and processing into their final form.
Relevant greenhouse gas Carbon dioxide (CO2) and nitrous oxide (N2O)
emissions
Indirect emissions Quantity of electricity consumed (MWh),
CO2 or CO2e.
period.
Unit for embedded emissions Tonnes CO2e emissions per tonne of goods,
reported separately for each type of goods, by
installation in the country of origin.
The fertilizer industry sector has to account for both direct emissions and indirect
emissions in the transitional period. Indirect emissions are to be reported separately.
Emissions should be reported in metric tonnes CO2 equivalent (tCO2e) emissions per tonne
of output. This figure should be calculated for the specific installation or production
process in the country of origin.
32
For certain goods, the imported quantities need to be converted to standardised tonnes that are
subsequently used for calculating the CBAM obligation. For example, for nitric acid, hydrous solutions
of ammonia and nitrogen-containing fertilizers, there will be a need to explicitly state the reference
concentration / nitrogen content (and form of nitrogen).
38
fertilizer industry sector. The aggregated goods category in the left hand column defines
monitoring.
Table 5-6: CBAM goods in the fertilizer sector
Aggregated goods Product CN Code Description

category
Nitric acid 2808 00 00 Nitric acid; sulphonitric acids
Urea 3102 10 Urea, whether or not in aqueous
solution
Ammonia 2814 Ammonia, anhydrous or in
aqueous solution
Mixed fertilizers 2834 21 00, 3102, 3105 2834 21 00 – Nitrates of
- Except 3102 10 (Urea) potassium
and 3105 60 00 3102 – Mineral or chemical
fertilizers, nitrogenous
- Except 3102 10 (Urea)
3105 – Mineral or chemical
fertilizers containing two or
three of the fertilizing elements
nitrogen, phosphorus, and
potassium; other fertilizers
- Except: 3105 60 00 – Mineral
or chemical fertilizers containing
the two fertilizing elements
phosphorus and potassium 33
The aggregated goods categories listed in the table above include both finished nitrogenous
fertilizer goods and relevant chemical precursor goods (intermediate products) that are
consumed in the production of nitrogenous fertilizer.
production process as specified in the Implementing Regulation, that are produced for use
in chemical fertilizer production, are to be considered 34. Table 5-7 below lists the possible
precursors by aggregated goods category and production route.
33
Only nitrogen (N) containing fertilizers have significant embedded emissions, therefore their precursors
are included in the CBAM.
34
Around 80% of all ammonia production is used as a chemical precursor for fertilizer production and
circa 97% of nitrogen fertilizers are derived from ammonia.
39
Table 5-7: Aggregated goods categories, their production routes and possibly relevant precursors

Production route
Ammonia Hydrogen, if separately produced for use in the
process 35.
Haber Bosch with steam
reforming
Haber Bosch with
gasification
Nitric Acid Ammonia (as 100% ammonia).
Urea Ammonia (as 100% ammonia).
Mixed fertilizer If used in the process: ammonia (as 100%
ammonia), nitric acid (as 100% nitric acid), urea,
mixed fertilizers (in particular salts containing
ammonium or nitrate).
For the production of mixed fertilizer, not all precursors will apply in every case. Also,
mixed fertilizer itself may be used as a precursor for its own category, depending on the
final formulation of the mixed fertilizer product required.
The final nitrogenous chemical fertilizer goods produced from the relevant precursors (in
bulk in integrated plants) are defined as complex goods as they include the embedded
emissions from relevant precursor goods.
The production of fertilizer sector goods is by a number of different process routes,

outlined below.
The system boundaries for chemical precursors and fertilizers are distinct and may, under
certain conditions, be added together to include all processes directly or indirectly linked
to the production processes for these goods, including input activities to the process, and
output activities from the process.
The following Figure 5-4 provides an overview of the different processes and process
routes for the production of nitrogenous fertilizer and its relevant precursors.
35
Where hydrogen from other production routes is added to the process, it shall be treated as a precursor
with its own embedded emissions.
40
Figure 5-4: System boundaries and value chain for the production of nitrogenous fertilizer
and its precursors – overview
Production of nitrogenous fertilizer and its precursors – overview

Ammonia Ammonia Ammonia (route Nitric acid Mixed fertilizer
Urea production
production (gas) production (coal) via separate H2) production production
Hydrogen
Natural gas Coal Ammonia Ammonia Ammonia
(various routes)
CO2 Nitric Acid
Urea
Steam
Gasification Other materials
reforming innovative Ostwald Urea incl. P,K
Haber-Bosch Haber-Bosch processes process production compounds
process process
Mixing /
Ammonia Ammonia Ammonia Nitric Acid Urea
granulation
Mixed fertilizers
Urea is used as a precursor in mixed fertilizer production but may also be used as a
convenient fertilizer on its own due to its high nitrogen content.
Mixed fertilizers comprise all kinds of nitrogen (N) containing fertilizers, including
ammonium nitrate, calcium ammonium nitrate, ammonium sulphate, ammonium
phosphates, urea ammonium nitrate solutions, as well as nitrogen-phosphorus (NP),
nitrogen-potassium (NK) and nitrogen-phosphorus-potassium (NPK) fertilizers.
5.5.3.1 Ammonia production process

Ammonia is synthesised from nitrogen and hydrogen via the Haber-Bosch process.
Hydrogen for the process is obtained by one of two production routes, by steam reforming
natural gas (or biogas), or by partial oxidation (gasification) of heavier hydrocarbons such
as coal or heavy fuel oil. With steam reformation natural gas is converted to hydrogen and
carbon dioxide (through primary and secondary steam reformation). The overall reaction
is highly endothermic and process heat is supplied by the combustion of natural gas or
other gaseous fuel. With partial oxidation (gasification) a synthesis gas containing
hydrogen is produced, which has to be purified before the it can be used for the next
production step. Ammonia is then synthesised from the hydrogen produced by either
production route and from nitrogen obtained from the air, at high temperature and pressure
in the presence of a catalyst. Any carbon monoxide produced by steam reforming or
gasification is almost all converted to carbon dioxide.
If hydrogen that is separately produced (i.e. by a different production process) is used in

the process, it is treated as a precursor, with its own embedded direct and indirect
emissions.
Direct emissions for both production routes result from the combustion of fuels, from the
use of fuels as a chemical feedstock for the process, or from process materials used for flue
gas cleaning. Indirect emissions result from electricity consumed by the process.
Note that ammonia produced is reported as 100% ammonia, whether in hydrous or

anhydrous form.
41
Also note that the stream of carbon dioxide from the production of ammonia is of high
purity and under certain conditions can be separated, captured and transferred elsewhere
for other uses e.g. for urea production.
5.5.3.2 Nitric acid (and sulphonitric acids) production process

Nitric acid is mostly produced via the oxidation of ammonia by Ostwald process. Ammonia
is first oxidised in the presence of a catalyst to form nitrogen oxide, which is then further
oxidised to nitrogen dioxide, followed by absorption in water in an absorption tower to
form nitric acid. The reaction is exothermic and heat and power may be recovered to the
process.
Ammonia (as 100% ammonia) is a relevant precursor, with its own embedded direct and
indirect emissions.
Direct emissions result from the combustion of fossil fuels, from materials used for flue
gas cleaning, and from N2O emissions from the production process (N2O emissions from
combustion are excluded). Indirect emissions result from electricity consumed by the
process.
Note that nitric acid produced is reported as 100% nitric acid.
5.5.3.3 Urea production process

Urea is synthesised by reacting ammonia and carbon dioxide together at high pressure, to
form ammonium carbamate, which is then dehydrated to form urea.
Ammonia (as 100% ammonia) is a relevant precursor, with its own embedded direct and
indirect emissions.
The ammonia and CO2 consumed by this production process are usually delivered from
other production processes on the same site.
5.5.3.4 Mixed fertilizers production process

A wide range of operations are included in the production of all kinds of nitrogen
containing mixed fertilizers (especially ammonium salts and NP, NK and NPK), such as
mixing, neutralisation 36, particle formation (such as by granulation or prilling), irrespective
of whether only physical mixing or chemical reactions take place.
Relevant precursors for the manufacture of mixed fertilizer are ammonia (as 100%
ammonia), nitric acid (as 100% nitric acid), urea and other mixed fertilizers (in particular
salts containing ammonium or nitrate), if used in the process.
Direct emissions result from the combustion of fossil fuels used in the process (such as for
driers, for heating input materials) or from process materials used for flue gas cleaning.
Indirect emissions result from electricity consumed by the process.
36
Nitrogen containing chemical fertilizers are produced by the neutralisation of an acid with ammonia to
form the corresponding ammonium salt. Fertilizers produced in this way include ammonium nitrate,
calcium ammonium nitrate, ammonium sulphate, ammonium phosphates, urea ammonium nitrate.
42
importer.
Table 5-8: Additional fertilizer sector parameters covered in the CBAM report

category
Ammonia 37 – Concentration, if hydrous solution.
Nitric acid 38 – Concentration (mass %).
Urea - Purity (mass % urea contained, % N contained).

Mixed fertilizers 39,40 Content of different forms of nitrogen in mixed fertilizer:
- Content of N as ammonium (NH4+);
- Content of N as nitrate (NO3–);
- Content of N as Urea;
- Content of N in other (organic) forms.
These additional parameters should be reported where relevant for the goods produced.
5.6 Iron and Steel sector


• Annex II, Section 2, Table 1 Mapping of CN codes to aggregated goods categories.
37
Both hydrous and anhydrous ammonia shall be reported jointly as 100% ammonia.
38
Amounts of nitric acid produced shall be monitored and reported as 100% nitric acid
39
The amounts of different nitrogen compounds contained in the final product should be recorded in
accordance with Regulation (EU) 2019/1009 laying down rules on the making available on the market
of EU fertilizing products
40
Regulation (EU) 2019/1009 of the European Parliament and of the Council laying down rules on the
making available on the market of EU fertilizing products.
See: http://data.europa.eu/eli/reg/2019/1009/2023-03-16
43
• Annex II, Section 3 Production routes, system boundaries, and relevant precursors, as specified in
sub-section: 3.11 – Sintered ore; 3.12 – Ferro-manganese, Ferro-chromium, Ferro-nickel; 3.13 – Pig
iron; 3.14 – DRI; 3.15 – Crude steel; 3.16 – Iron or steel products.
The quantity of declared iron and steel sector good imported into the EU should be
expressed in metric tonnes. As a reporting declarant, you should report the quantity of
CBAM goods imported into the EU.
Industrial sector Iron and steel

Production unit of goods Tonnes (metric), reported separately for each
production process in the country of origin
Associated activities Producing, melting or refining iron or steel or
ferrous alloys; manufacture of semi-finished
and basic steel products.
Relevant greenhouse gas Carbon dioxide (CO2)
CO2 or CO2e.
period.
reported separately for each type of goods, by
installation in the country of origin
The iron and steel sector has to account for both direct emissions and indirect emissions in
the transitional period. Indirect emissions are to be reported separately 41. Emissions should
be reported in metric tonnes CO2 equivalent (tCO2e) emissions per tonne of output. This
figure should be calculated for the specific installation or production process in the country
of origin.
iron and steel industry sector. The aggregated goods category in the left hand column
41
44
defines groups for which joint ‘production processes’ are to be defined for the purpose of
monitoring.
Table 5-9: CBAM goods in the iron and steel sector
Aggregated goods Product CN Description

category Code
Sintered Ore 42 2601 12 00 Agglomerated iron ores and concentrates,
other than roasted iron pyrites
Pig iron 7201 Pig iron and spiegeleisen 43 in pigs, blocks
or other primary forms
7205 44 Some products under 7205 (Granules and
powders, of pig iron, spiegeleisen, iron, or
steel) may be covered here
Ferro-alloy: FeMn 7202 1 Ferro-manganese (FeMn)
Ferro-alloy: FeCr 7202 4 Ferro-chromium (FeCr)

Ferro-alloy: FeNi 7202 6 Ferro-nickel (FeNi)
DRI 7203 Ferrous products obtained by direct
reduction of iron ore and other spongy
ferrous products
Crude steel 7206, 7207, 7206 – Iron and non-alloy steel in ingots
7218 and 7224 or other primary forms (excluding iron of
heading 7203)
7207 – Semi-finished products of iron or
non-alloy steel
7218 – Stainless steel in ingots or other
primary forms; semi-finished products of
stainless steel
7224 – Other alloy steel in ingots or other
primary forms; semi-finished products of
other alloy steel
Iron or steel Includes: 7205, 7205 – Granules and powders, of pig iron,
products 45 7208-7217, spiegeleisen, iron or steel (if not covered
7219-7223, under category pig iron)
7225-7229, 7208 – Flat-rolled products of iron or non-
7301-7311, alloy steel, of a width of 600 mm or more,
7318 and 7326 hot-rolled, not clad, plated or coated
42
This aggregated goods category includes all kinds of iron ore pellet production (for sale of pellets as
well as for direct use in the same installation) and sinter production.
43
Pig iron containing alloy ferro-manganese.
44
Only some products of this CN code will qualify as “pig iron”, while other goods of this code are
classified as “iron or steel products”
45
This aggregated goods category includes semi-finished and finished products.
45
category Code
7209 – Flat-rolled products of iron or non-
alloy steel, of a width of 600 mm or more,
cold-rolled (cold-reduced), not clad, plated
or coated
alloy steel, of a width of 600 mm or more,
clad, plated or coated
alloy steel, of a width of less than 600 mm,
not clad, plated or coated
alloy steel, of a width of less than 600 mm,
clad, plated or coated
7213 – Bars and rods, hot-rolled, in
irregularly wound coils, of iron or non-
alloy steel
7214 – Other bars and rods of iron or non-
alloy steel, not further worked than forged,
hot-rolled, hot-drawn or hot-extruded, but
including those twisted after rolling
7215 – Other bars and rods of iron or non-
alloy steel
7216 – Angles, shapes and sections of iron
or non-alloy steel
7217 – Wire of iron or non-alloy steel
7219 – Flat-rolled products of stainless
steel, of a width of 600 mm or more
7220 – Flat-rolled products of stainless
steel, of a width of less than 600 mm
irregularly wound coils, of stainless steel
7222 – Other bars and rods of stainless
steel; angles, shapes and sections of
stainless steel
7223 – Wire of stainless steel
7225 – Flat-rolled products of other alloy
steel, of a width of 600 mm or more
7226 – Flat-rolled products of other alloy
steel, of a width of less than 600 mm
irregularly wound coils, of other alloy steel
46
category Code
7228 – Other bars and rods of other alloy
steel; angles, shapes and sections, of other
alloy steel; hollow drill bars and rods, of
alloy or non-alloy steel
7229 – Wire of other alloy steel
7301 – Sheet piling of iron or steel,
whether or not drilled, punched or made
from assembled elements; welded angles,
shapes and sections, of iron or steel
7302 – Railway or tramway track
construction material of iron or steel, the
following: rails, check-rails and rack rails,
switch blades, crossing frogs, point rods
and other crossing pieces, sleepers (cross-
ties), fish- plates, chairs, chair wedges,
sole plates (base plates), rail clips,
bedplates, ties and other material
specialised for jointing or fixing rails
7303 – Tubes, pipes and hollow profiles,
of cast iron
7304 – Tubes, pipes and hollow profiles,
seamless, of iron (other than cast iron) or
steel
7305 – Other tubes and pipes (for
example, welded, riveted or similarly
closed), having circular cross-sections, the
external diameter of which exceeds 406,4
mm, of iron or steel
7306 – Other tubes, pipes and hollow
profiles (for example, open seam or
welded, riveted or similarly closed), of
iron or steel
7307 – Tube or pipe fittings (for example,
couplings, elbows, sleeves), of iron or steel
7308 – Structures (excluding prefabricated
buildings of heading 9406) and parts of
structures (for example, bridges and
bridge-sections, lock- gates, towers, lattice
masts, roofs, roofing frameworks, doors
and windows and their frames and
thresholds for doors, shutters, balustrades,
pillars and columns), of iron or steel;
plates, rods, angles, shapes, sections, tubes
and the like, prepared for use in structures,
of iron or steel
47
category Code
7309 – Reservoirs, tanks, vats and similar
containers for any material (other than
compressed or liquefied gas), of iron or
steel, of a capacity exceeding 300 l,
whether or not lined or heat-insulated, but
not fitted with mechanical or thermal
equipment
7310 – Tanks, casks, drums, cans, boxes
and similar containers, for any material
(other than compressed or liquefied gas),
of iron or steel, of a capacity not exceeding
300 l, whether or not lined or heat-
insulated, but not fitted with mechanical or
thermal equipment
7311 – Containers for compressed or
liquefied gas, of iron or steel
7318 – Screws, bolts, nuts, coach screws,
screw hooks, rivets, cotters, cotter pins,
washers (including spring washers) and
similar articles, of iron or steel
7326 – Other articles of iron or steel
The aggregated goods categories listed in the table above include both finished goods and
precursor goods (intermediate products) that are consumed in the production of iron or
steel products.
5-10 below lists the possible precursors by aggregated goods category and production
route.

Production route
Sintered Ore None
Ferro alloys (FeMn, FeCr, FeNi) Sintered ore, if used in the process.
Pig iron Hydrogen, sintered ore, ferro alloys, pig iron/DRI
(the later if obtained from other installations or
Blast furnace route
production processes and used in the process).
Smelting reduction
48
Production route
DRI (Direct Reduced Iron) Hydrogen, sintered ore, ferro alloys, pig iron/DRI
(the latter if obtained from other installations or
production processes and used in the process).
Crude steel Ferro alloys, pig iron, DRI, crude steel (the latter if
obtained from other installations or production
Basic oxygen
processes and used in the process).
steelmaking
Electric arc furnace
Iron or steel products Ferro alloys, pig iron, DRI, crude steel, iron or steel
products (if used in the process).
Not all precursors will apply in every case. For example, hydrogen may only become
relevant in the future.
Note in particular that in some cases an aggregated goods category may be precursor for
its own category. This is best explained by an example:
Example: If an installation produces screws and nuts from steel rods, then the rods are
the precursor, but both rods and screws and nuts are included in the same aggregated
goods category.
The embedded emissions of the screws and nuts will be composed of the emissions of
the production process (heat applied for making the rods workable, and for annealing of
the final product) plus the embedded emissions of the steel rods. Note that this is
important because the mass of the precursor rods and the mass of the final product
screws and nuts will not be the same – if e.g. 20% of the original mass are cut away (and
disposed of as scrap), 100 t precursor are required for 80 t of final product.
Some types of iron and steel products have been excluded from the scope of the CBAM.
In particular, these include certain other types of ferro alloys under CN 7202 46 and CN
7204 – ferrous waste and scrap.
The production of iron and steel sector goods is by a number of different process routes,
outlined below.
5.6.3 Definition and explanation of relevant production processes and emissions

covered
The system boundaries for precursors and iron or steel finished products are distinct and
may, under certain conditions, be added together to include all processes directly or
46
Other ferro-alloys not covered by CBAM include ferro-silicon, ferro-silico-manganese, ferro-silico-
chromium, ferro-molybdenum, ferro-tungsten and ferro-silico-tungsten etc.
49
indirectly linked to the production processes for these goods, including input activities to
the process, and output activities from the process.
The following diagram illustrates the variety of different routes by which iron or steel
products may be produced.
Figure 5-5: System boundaries and value chain for the production of iron or steel products
Production of iron or steel products – overview
The production of precursor and finished goods is by a number of different process routes,
outlined in the following sections.
5.6.3.1 Sintered ore production process

This aggregated goods category includes all kinds of iron ore pellet production (for sale of
pellets as well as for direct use in the same installation) and sinter production. Pelletisation
and sintering are complementary process routes for preparing and agglomerating iron
oxide raw materials for use in iron and steel making. In pelletisation, iron oxide raw
materials are ground and combined with additives to form pellets, which are then thermally
treated. In sintered ore production, iron oxide raw materials are mixed with coke breeze
and other additives before the mixture is sintered together in a kiln, forming a porous
material similar to clinker, called ‘sinter’. Sinter is typically produced and used at the
steelworks. Pellets may be produced at the steelworks or at a distance at mine sites.
There are no relevant precursors for this production process.
Note that ferro-alloy pellets and sinter produced from iron ores may also be covered by
this production process (for CN code 2601 12 00).
The following Figure 5-6 shows the system boundaries for the embedded emissions of
sinter or iron ore pellets.
50
Figure 5-6: System boundaries of the sintered ore production process
Sintered ore production process
Direct emissions result from the combustion of fuels including coke, waste gases (directly
from the process or indirectly from other sources of waste gases in the steelworks). Indirect
emissions result from electricity consumed by the process.
5.6.3.2 Ferro-alloy for FeMn, FeCr,and FeNi production processes

This process covers the production of the alloys ferro-manganese (FeMn), ferro-chromium
(FeCr) and ferro-nickel (FeNi), that are identified under CN codes 7202 1, 7202 4 and 7202
6. Other iron materials with significant alloy content such as spiegeleisen are not covered
here (see section 5.6.3.3). However, nickel pig iron (NPI) is included if the nickel content
is greater than 10%; otherwise, if less than 10% NPI is covered by the ‘Pig iron – blast
furnace production route’.
The different ferro-alloys are produced by reductive smelting with the addition of a
reducing agent such as coke to the EAF, along with other additives. Several different types
of EAF are used, depending on the ferro-alloy being produced. Following EAF smelting,
liquid metal alloy is tapped and cast in moulds. The solidified cast metal is then crushed
or granulated depending on customer requirements.
A relevant precursor is sintered ore (if used in the process).
Note that raw material inputs for ferro-alloys include pellets and sinter that are produced
under the separate production process (for CN code 2601 12 00) for ‘Sintered ore’.
The following Figure 5-7 shows the system boundaries of the relevant processes for ferro-
alloy production.
51
Figure 5-7: System boundaries of the Ferro-alloy production process.
Ferro-alloy production process – EAF reductive smelting
Sinter or pellets
Coke Silicon or FeSi Aluminium
Electrodes
Electric arc (or CO2

other) furnace Emissions
Lime, other
additives
Waste gases Ferro Alloy

System boundaries:
to other processes embedded emissions
and power plant of ferro-alloys (generic)
Direct emissions result from fossil fuel inputs (coal, coke) used both for combustion and
as a reducing agent, from process emissions including from the graphite electrodes and
electrode pastes, from process materials such as lime, limestone and other additives.
Indirect emissions are from electricity.
5.6.3.3 Pig iron - Blast furnace production route

The blast furnace production route produces liquid pig iron (“hot metal”) that may be
alloyed (e.g. spiegeleisen and nickel pig iron or NPI 47) or non-alloyed. The main
production unit for this production process is the blast furnace. Inputs into the blast furnace
include iron ore pellets or sintered ore, fuels and other raw materials. Inside the blast
furnace iron oxide is reduced to iron metal. The hot metal produced is then tapped and is
either cast, or is directly converted to crude steel in a sequential step by the basic oxygen
converter. This step is covered under a different production process, the crude steel – basic
oxygen steelmaking production route.
Relevant precursors (if used in the process) are: sintered ore; pig iron or DRI from other
installations or production processes; ferro-alloys FeMn, FeCr, FeNi; and hydrogen.
The following Figure 5-8 shows the system boundaries of the blast furnace production
route for producing pig iron.
47
NPI is covered by this production process if the nickel content is lower than 10%, otherwise if more than
10% it is covered under the ferro-alloy production process.
52
Figure 5-8: System boundaries of the Pig iron - blast furnace production route
Pig iron – Blast furnace production route
Direct emissions result from fossil fuel inputs (coke, coal, fuels oils, natural gas, coal),
used both for combustion and as a reducing agent, from other fuels (biomass), from process
emissions including from process materials such as limestone and other carbonates.
Indirect emissions are from electricity.
5.6.3.4 Pig iron - Smelting reduction production route

Smelting reduction produces pig iron from precursor sintered ore, iron ore pellets, (or
ironmaking residues), using coal (not coke) as a reductant. The process comprises two
steps, the reduction of iron ore followed by melting to produce pig iron / hot metal.
Relevant precursors (if used in the process) are: sintered ore; pig iron or DRI from other
installations or production processes; ferro-alloys FeMn, FeCr, FeNi; and hydrogen.
The following Table 5-9 shows the system boundaries of the smelting reduction production
route for producing pig iron.
53
Figure 5-9: System boundaries of the Pig iron - smelting reduction production route
Pig iron – Smelting reduction production route
Direct emissions result from fossil fuel inputs (natural gas, coal), used both for combustion
and as a reducing agent, from other fuels (biomass, or biogas), from process emissions
including from process materials such as limestone. Indirect emissions are from electricity.
5.6.3.5 Direct Reduced Iron (DRI) production process

Direct reduction involves the production of solid primary iron from high grade iron ores
(pellets, sinter or concentrates), using natural gas, coal or hydrogen as a reducing agent.
The solid product is called direct reduced iron (DRI), of different types, for example, ‘iron
sponge’ and hot briquetted iron (HBI). Some DRI is used as a feedstock directly in EAFs
or other downstream processes. It is expected that production routes using hydrogen will
play a major role in decarbonising the steel industry in coming years.
Relevant precursors (if used in the process) are: sintered ore; hydrogen; pig iron or DRI
from other installations or production processes; and ferro-alloys FeMn, FeCr, FeNi.
Although there are several different processes used in practice, the high-level system
boundaries are very similar and can therefore be represented on a single diagram.
The following Table 5-10 shows the system boundaries of the relevant processes for DRI
production.
54
Figure 5-10: System boundaries of the DRI production process
DRI production process
Direct emissions result from fossil fuel inputs (natural gas, coal), used both for combustion
and as a reducing agent, from other fuels (biomass, or biogas), from process emissions
including from process materials such as limestone. Indirect emissions are from electricity.
5.6.3.6 Crude steel - Basic oxygen steelmaking production route

If the basic oxygen steelmaking production route starts with hot metal (liquid pig iron), the
hot metal is directly converted to crude steel by the basic oxygen converter or furnace
(BOF) as part of a continuous process. Following the converter, a steel decarburisation
process by argon oxygen decarburisation (AOD) or vacuum oxygen decarburisation
(VOD) may be performed, followed by various secondary metallurgical processes such as
vacuum degassing to remove dissolved gases. Crude steel is then cast into its primary
forms by continuous casting or ingot casting, which may be followed by hot-rolling or
forging to obtain the semi-finished crude steel products (under CN codes 7207, 7218 and
7224).
Relevant precursors (if used in the process) are: pig iron, DRI; ferro-alloys FeMn, FeCr,
FeNi; and crude steel from other installations or production processes, if used.
55
Figure 5-11: System boundaries of the basic oxygen steelmaking process – shown alongside those
for the Blast furnace – liquid pig iron production route, and other related processes
Crude steel – Basic oxygen steelmaking alongside other related activities
In integrated steel plants, liquid pig iron that is directly charged to the oxygen converter is
the product which separates the production process for pig iron (bottom left in the above
Figure 5-11) from the production process of crude steel (bottom right, above).
The integrated blast furnace / basic oxygen furnace (BF/BOF) steelmaking process is by
far the most complex steel making process and is characterised by networks of
interdependent material and energy flows between the various production units. Note that
coke (top left) is treated as a raw material with no embedded emissions.
56
5.6.3.7 Crude steel - EAF steelmaking production route
The direct smelting of materials which contain iron is usually performed in an electric arc
furnace (EAF). Feedstocks for EAF routes are metallic iron in particular ferrous scrap 48
and/or Direct Reduced Iron (DRI). Where significant amounts of DRI are used, one of the
various EAF-DRI routes applies. Following EAF smelting, a steel decarburisation process
by argon oxygen decarburisation (AOD) or vacuum oxygen decarburisation (VOD) may
be performed, followed by various secondary metallurgical processes such as
desulphurisation and degassing to remove dissolved gases. Electricity is the main energy
input to the EAF.
Relevant precursors (if used in the process) are: pig iron, DRI; ferro-alloys FeMn, FeCr,
FeNi; and crude steel from other installations or production processes, if used
Note that only primary hot-rolling and rough shaping by forging to obtain the semi-finished
products under CN codes 7207, 7218 and 7224 are included in this aggregated goods
category. All other rolling and forging processes are included in the aggregated goods
category ‘iron or steel products’.
There are several different EAF production routes, for crude steel and crude alloy steel,
which are broadly similar and are shown jointly in Figure 5-12 below.
Figure 5-12: System boundaries of the Crude steel - EAF steelmaking production route.
Crude steel – EAF alloy and non-alloy steel production route
DRI
Scrap Electrodes Lime
(various routes)
Optional: Other
materials and fuels
EAF (electric CO2
arc furnace) Emissions
Electricity*
System boundaries:
Crude steel
*Electricity is mentioned here embedded emissions
explicitly as it is the main of crude steel
energy input to the process. (EAF route)
Alloy components
Scrap (FeNi, FeCr, Electrodes Lime
FeMn)
Pig iron,
DRI, NPI
EAF (electric
CO2
arc furnace)
Optional: Other Emissions
materials and fuels & AOD / VOD
Electricity*
System boundaries:
*Electricity is mentioned here Crude alloy steel embedded emissions
explicitly as it is the main of crude alloy steel
energy input to the process. (EAF route)
48
Where only post-consumer scrap is used, it is assumed to have zero embedded emissions
57
Direct emissions result from fossil fuels (natural gas, coal, fuel oil), waste gases from other
processes, and from process emissions including from the graphite electrodes and electrode
pastes, from process materials such as lime, and from carbon contained with the ferrous
scrap and alloys entering the process. Indirect emissions are from electricity.
5.6.3.8 Iron or steel products production process

Iron or steel products are produced from the further processing of crude steel, semi-finished
products, as well as other final steel products by all kinds of forming and finishing steps
including: re-heating, re-melting, casting, hot rolling, cold rolling, forging, pickling,
annealing, plating, coating, galvanizing, wire drawing, cutting, welding, finishing.
Relevant precursors (if used in the process) are: crude steel; pig iron, DRI; ferro-alloys
FeMn, FeCr, FeNi; and other iron or steel products.
The following Figure 5-13 shows the system boundaries for iron or steel products.
Figure 5-13: System boundaries of the iron or steel products production process
Iron or steel products

Crude steel
(depending on Fuels (incl.
production waste gases)
route)
Production of CO2
basic steel Emissions
products**
** This includes in a
generic way all Basic steel
typical productions products System boundaries:
steps, such as embedded emissions
casting, hot and
of basic steel products
cold rolling, coating
etc. (may apply to all steel routes)
Direct emissions result from combustion of fuels and process emissions from flue gas
cleaning, depending on the different combination of production steps carried out in
producing the final iron or steel goods. Indirect emissions are from electricity.
Note that for final iron or steel products that contain more than 5% by mass of other
materials, e.g. insulation materials in CN code 7309 00 30 (reservoirs, tanks, vats and
similar containers for any material (other than compressed or liquefied gas), of iron or
steel, of a capacity exceeding 300 l, lined or heat-insulated), only the mass of iron or steel
shall be reported as the mass of the goods produced.
58
The following table lists out the additional information for CBAM goods that should be
provided by the operator, along with data on embedded emissions, in their emissions data
communication to you the importer.
Table 5-11: Additional iron and steel sector parameters covered in the CBAM report
Aggregated good Reporting requirement

category
Sintered Ore – None.
Pig Iron – The main reducing agent used.
– Mass % of Mn, Cr, Ni, total of other alloy elements.
FeMn – Ferro- – Mass % of Mn and carbon.

Manganese
FeCr – Ferro- – Mass % of Cr and carbon.
Chromium
FeNi – Ferro-Nickel – Mass % of Ni and carbon.
DRI (Direct Reduced – The main reducing agent used.

Iron)
Crude steel – The main reducing agent of the precursor, if known.
– Content of alloys in steel – expressed as:
– Tonnes scrap used for producing one tonne crude steel.
– % of scrap that is pre-consumer scrap.
Iron or steel products – The main reducing agent used in precursor production, if
known.
– Content of alloys in steel – expressed as:
– Mass % of materials contained which are not iron or steel,

if their mass is more than 1% to 5% of the total good’s
mass.
– Tonnes scrap used for producing one tonne of the

product.
59
Aggregated good Reporting requirement
category
You will need to report the additional parameters in your CBAM Report when the iron or
steel good is imported to the EU under the CBAM.
5.7 Aluminium sector
The textbox below signposts the sector-specific sections in the Implementing Regulation,

categories.
precursors, as specified in sub-section: 3.17 – Unwrought aluminium and 3.18
– Aluminium products.
The quantity of declared aluminium goods imported into the EU should be expressed in
metric tonnes. As an operator, you should record the quantity of CBAM good(s) produced
by the installation or production process, for the purposes of reporting.
Industrial sector Aluminium

Production unit of goods Tonnes (metric), reported separately for each
production process in the country of origin.
Associated activities Producing unwrought aluminium from alumina,
or secondary raw materials (aluminium scrap),
by metallurgical, chemical or electrolytic
means; manufacture of semi-processed and
basic aluminium products.
Relevant greenhouse gases Carbon dioxide (CO2) and perfluorocarbons
(CF4 and C2F6)
CO2 or CO2e.
period.
60
Industrial sector Aluminium
reported separately for each type of good, by
installation in the country of origin.
The aluminum sector should account for both direct emissions and indirect emissions in
the transitional period. Indirect emissions are to be reported separately 49. Emissions should
be reported in metric tonnes CO2 equivalent (tCO2e) emissions per tonne of output. This
figure should be calculated for the specific installation or production process in your
country of origin.
5.7.2 Definition and explanation of sector goods covered
aluminium industry sector. The aggregated goods category in the left hand column defines
monitoring.
Table 5-12: CBAM goods in the aluminium sector
Aggregated Product Description

goods CN Code
category
Unwrought 7601 Unwrought aluminium
aluminium
Aluminium 7603 – 7603 – Aluminium powders and flakes
products 7608, 7604 – Aluminium bars, rods and profiles
7609 00
00, 7610, 7605 – Aluminium wire
7611 00 7606 – Aluminium plates, sheets and strip, of a
00, 7612, thickness exceeding 0,2 mm
7613 00
7607 – Aluminium foil (whether or not printed or
00, 7614,
backed with paper, paper-board, plastics or similar
7616
backing materials) of a thickness (excluding any
backing) not exceeding 0,2 mm
7608 – Aluminium tubes and pipes
7609 00 00 – Aluminium tube or pipe fittings (for
example, couplings, elbows, sleeves)
49
61
Aggregated Product Description
goods CN Code
category
7610 – Aluminium structures (excluding prefabricated
buildings of heading 9406) and parts of structures (for
example, bridges and bridge-sections, towers, lattice
masts, roofs, roofing frameworks, doors and windows
and their frames and thresholds for doors, balustrades,
pillars and columns); aluminium plates, rods, profiles,
tubes and the like, prepared for use in structures
7611 00 00 – Aluminium reservoirs, tanks, vats and
similar containers, for any material (other than
compressed or liquefied gas), of a capacity exceeding
300 litres, whether or not lined or heat-insulated, but
not fitted with mechanical or thermal equipment
7612 – Aluminium casks, drums, cans, boxes and
similar containers (including rigid or collapsible
tubular containers), for any material (other than
compressed or liquefied gas), of a capacity not
exceeding 300 litres, whether or not lined or heat-
insulated, but not fitted with mechanical or thermal
equipment
7613 00 00 – Aluminium containers for compressed
or liquefied gas
7614 – Stranded wire, cables, plaited bands and the
like, of aluminium, not electrically insulated
7616 – Other articles of aluminium
The aggregated goods categories listed in the table above include both finished aluminium
products and a precursor ‘unwrought aluminium’ that is consumed in the production of
aluminium products.
5-13 lists the possible precursors by aggregated goods category and production route
below.

Production route
Unwrought aluminium None for primary aluminium
Primary aluminium
Secondary aluminium
62
Production route
For secondary aluminium – unwrought aluminium
from other sources, if used in the process 50
Aluminium products Unwrought aluminium (differentiated between
primary and secondary aluminium, if known), other
aluminium products (if used in the production
process).
Unwrought aluminium is produced by several production routes (‘primary aluminium’ for

electrolytic smelting, ‘secondary aluminium’ for the melting/recycling of scrap) as metal
ingots, blocks, billets, slabs or similar. It is defined as a ‘simple good’, as the raw materials
(carbon anodes and alumina for primary aluminium, scrap for secondary aluminium) and
fuels used in its manufacture are themselves considered to have zero embedded emissions.
The aluminium goods listed above include most types of aluminium product
manufactured 51. Aluminium products are defined as complex goods as they include the
embedded emissions from the precursor unwrought aluminium.
Figure 5-14: System boundaries and value chain of aluminium products.
System boundaries and value chain for aluminium products
The difference in primary aluminium smelting route in the above diagram is due to the
different electrode materials used, i.e. pre-baked or Søderberg anodes.
50
Note that if the product from secondary aluminium production route contains more than 5% alloying
elements, the embedded emissions of the product shall be calculated as if the mass of alloying elements
were unwrought aluminium from primary smelting.
51
Excludes categories CN 7615 for certain household articles and CN 7602 00 aluminium scrap.
63
The system boundaries for the precursor unwrought aluminium and for aluminium
products are distinct and may, under certain conditions, be added together to include all
processes directly or indirectly linked to the production processes for these goods,
including input activities to, and output activities from the process.
5.7.3.1 Unwrought aluminium - Primary (electrolytic) smelting production route

Primary aluminium is produced by the electrolysis of alumina 52 in electrolytic cells.
During electrolysis, aluminium is reduced and oxygen from the alumina is liberated and
combines with the carbon anode to form carbon dioxide and carbon monoxide – the carbon
anodes in the primary aluminium process are therefore continuously consumed during the
process.
Primary aluminium cell systems vary according to the type of anode used. The ‘Pre-baked’
electrolytic cell uses multiple pre-baked carbon anodes that must be regularly replaced.
The ‘Søderberg’ electrolytic cell uses a single continuous carbon anode, which is self-
baked in situ within the cell by means of the heat released during the electrolytic process
within the smelter; ‘green’ anode paste briquettes are added at the top while the anode is
consumed at the bottom. Molten aluminium is deposited at the cathode and collects at the
bottom of the cell, where it is periodically withdrawn by vacuum siphons into crucibles
before being transported to the casting plant. At the casting plant molten aluminium is held
in holding furnaces for further processing prior to casting metal ingots, blocks, billets, slabs
or similar; small quantities of clean commercial scrap may also be added at this stage.
There are no relevant precursors for primary aluminium, as the raw material constituents
used by both types of cell – alumina, pre-baked carbon anodes, green anode paste
briquettes, cryolite and other additives – are considered to be raw materials and so have
zero embedded emissions.
Figure 5-15: System boundaries of the Unwrought aluminium - primary smelting production route
Unwrought aluminium – Primary smelting
Pre-baked Anode paste Optional:

Alumina
anodes (Søderberg route) Fuels
Primary CO2 + PFC

Electricity*
smelting Emissions
Unformed System boundaries:

*Electricity is mentioned here aluminium embedded emissions
explicitly as it is the main of aluminium
energy input to the process.
(primary smelting)
52
Alumina is purified aluminium oxide produced by beneficiation of bauxite ore via the Bayer process.
Production of alumina usually takes place at a different site to primary aluminium production for
logistical and power supply reasons
64
Direct emissions result from any fossil fuels used for drying or pre-heating of the raw
material inputs, from any fuels used by the casting plant, or from process materials such
as from the consumption of electrodes or electrode paste, or from flue gas cleaning (from
soda ash or limestone, if used). Indirect emissions result from electricity consumed by the
process. There are also PFC emissions that must be accounted for.
5.7.3.2 Unwrought aluminium - Secondary melting (recycling) production route

Secondary aluminium is produced mainly from post-consumer aluminium scrap collected
for recycling (although unwrought aluminium may also be separately added). Scrap is
sorted according to type (cast or wrought alloy) and the sort of pre-treatment measures
required (e.g. de-coating, de-oiling), and is then re-melted in the appropriate type of
furnace (typically rotary or reverberatory, but induction furnaces may also be used) before
further processing including: alloying, melt treatment (addition of salt or chlorination) and
finally casting metal ingots, blocks, billets, slabs or similar. Typical fuels used are natural
gas, LPG or fuel oil.
Secondary melting (recycling) of aluminium uses aluminium scrap as main input.
A relevant precursor is unwrought aluminium from other sources, if used in the process.
The following Figure 5-16 shows the system boundaries of the relevant processes for
secondary aluminium production.
Figure 5-16: System boundaries of the Unwrought aluminium - secondary melting production
route
Unwrought aluminium – Secondary melting
Aluminium scrap Fuels
Secondary
CO2
production
Emissions
(Re-melting)
Unformed System boundaries:

aluminium embedded emissions
of aluminium
(secondary smelting)
Direct emissions result from any fossil fuels used for drying, pre-heating or pre-treatment
(combustion of the related residues e.g. if scrap is painted) of the scrap raw materials; from
any fuels used by the casting plant; and from fuels used in processing skimmings and slag
65
recovered from the process. Direct emissions may also result from flue gas cleaning (from
soda ash or limestone, if used). Indirect emissions result from electricity consumed by the
process including electricity consumed by induction furnaces. There are no PFC emissions
from the secondary aluminium process.
Note that where the product of this process contains more than 5% alloying elements, the
embedded emissions of the product shall be calculated as if the mass of alloying elements
5.7.3.3 Aluminium products production process

Aluminium products are produced by the further processing of precursor unwrought
aluminium (alloyed or un-alloyed). Aluminium products are produced by a variety of
forming processes including extrusion, casting, hot and cold rolling, forging and drawing.
Extrusion is a common process used to produce aluminium profiles. Hot and cold rolling
may be used to produce plate, sheet and foil. Casting may be used to produce complex
forms.
Relevant precursors are unwrought aluminium, if used in the production process (primary
and secondary aluminium should be treated separately, if data is known, as each has
different embedded emissions), and aluminium products, if used in the production process.
The following Figure 5-17 shows the system boundaries of the relevant processes for
aluminium products.
Figure 5-17: System boundaries of aluminium products production process
Aluminium products production process
Direct emissions result from any fossil fuels used in the forming processes carried out (e.g.
natural gas used for pre-heating aluminium billets in holding furnaces, prior for forging).
Direct emissions may also result from flue gas cleaning. Indirect emissions result from
66
electricity consumed by the process. There are no PFC emissions resulting from aluminium
products forming processes.
Note that where the product of this process contains more than 5% alloying elements, the
embedded emissions of the product should be calculated as if the mass of alloying elements
Also note that for products that contain more than 5% by mass of other materials, e.g.
insulation materials in CN code 7611 00 00 only the mass of aluminium shall be reported
as the mass of the goods produced.
The following table lists out the additional information for CBAM goods that should be
provided by the operator, along with data on embedded emissions, in their emissions data
communication to you the importer.
Table 5-14: Additional aluminium sector parameters covered in the CBAM report

category
Unwrought aluminium – Tonnes of scrap used for producing one tonne of the
unwrought aluminium product.
– 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
unwrought aluminium product.
– Content of alloys in aluminium: If the total content of

elements other than aluminium exceeds 1%, the total
percentage of such elements.
67
6 REPORTING OBLIGATIONS
6.1.1 Reporting direct and indirect embedded emissions
During the transitional period you need to report both ‘direct emissions’ 53 and ‘indirect
emissions’ 54.
Direct embedded emissions are the emissions attributed to the relevant production process
producing the good, based on the producing installation’s direct emissions, emissions from
relevant heat flows, material flows, waste gases (if relevant) and direct embedded
emissions from any relevant precursor.
Indirect embedded emissions are the indirect emissions attributed to the relevant
production process producing goods at the producing installation, and indirect embedded
emissions from any relevant precursors.
A cross-sectoral rule is that where several production routes are used at the same
installation for producing goods falling under the same CN code, and these routes are
assigned to separate production processes, the embedded emissions of those goods should
be calculated separately for each production route.
Embedded emissions in precursor goods
The operator should include the embedded emissions in precursor goods (both direct and
indirect emissions, as above) in the calculation of total embedded emissions for a final
good, making this a ‘complex good’. The embedded emissions of the relevant precursor
goods 55 are added to embedded emissions of the complex good.
6.1.2 Units for reporting embedded emissions
The unit used for reporting embedded greenhouse gas is ‘tonne of CO2e 56’, which means
one metric tonne of carbon dioxide (‘CO2’), or an amount of any other greenhouse gas
listed in Annex I with an equivalent (‘e’) global warming potential; i.e. where relevant,
N2O and PFCs emissions should be converted to their ‘tCO2e’ value.
For reporting purposes embedded emissions data should be rounded to whole tonnes CO2e
over the reporting period. Parameters used to calculate the reported embedded emissions
should be rounded to include all significant digits, to a maximum of 5 decimal places. The
level of rounding required for parameters used in such calculations will depend on the
accuracy and precision of the measurement equipment used.
53
‘direct emissions’ mean emissions from the production processes of goods including emissions from the
production of heating and cooling consumed during the production processes, regardless of the location
of the production of the heating and cooling;
54
‘indirect emissions’ mean emissions from the production of electricity, which is consumed during the
production processes of goods, regardless of the location of the production of the consumed electricity.
55
Where a precursor is itself a complex good, this process is repeated recursively until no more precursors
are relevant.
56
‘tonne of CO2e’ means one metric tonne of carbon dioxide (‘CO2’), or an amount of any other
greenhouse gas listed in Annex I with an equivalent global warming potential
68
6.1.3 Embedded emissions
The concept of embedded emissions, for the purposes of the CBAM, is based on, but not
fully aligned with the principles and requirements for a carbon footprint of products (CFP).
A CFP is usually understood as an amount of GHG-emissions (expressed as kg or t CO2e)
per declared unit, (e.g. a tonne of good) based on a life-cycle perspective covering, all
significant emissions from upstream and downstream processes (called life cycle stages),
from mining and production to transport, use and end-of-life.
The difference from the CFP scope is because the CBAM is intended to cover the same
emissions as would be covered by the EU ETS if the production were situated in the EU.
The system boundaries of emissions covered by the EU ETS, and therefore the CBAM,
are narrower than those in a CFP. Downstream emissions (emissions from the use and
end-of-life) of the products are outside the scope of the EU ETS and the CBAM. Emissions
from transport of materials between sites and from processes further upstream are also not
included. Figure 6-1 summarizes this graphically.
For the purpose of determining CBAM embedded emissions at a product level, the starting
point are emissions of an installation. The installation’s emissions are split (‘attributed’) to
emissions of its production processes. Then any relevant embedded emissions of precursor
materials are added, and the result is divided by the activity level of each production
process, thereby resulting in ‘specific embedded emissions’ of the goods resulting from
the production process.
These considerations are reflected in the definitions of direct and indirect emissions, as set
out in the CBAM Regulation, and in its Annex IV which lays down the basic calculation
approach, which in particular requires taking into account precursor materials.
69
Figure 6-1: Comparison of product environmental footprint, product carbon footprint, and the
specific partial carbon footprint that are to be used for determining embedded emissions in the
CBAM.
Comparison of scopes in product footprints and the requirements of the CBAM

Other
Upstream Production of Production
Use stage End of life emissions
processes precursors process
• Mining • If applicable (only • Point of MRV • Including • Re-use
(water, air)
• Transport for complex • Producer outside distribution • recycling
• Etc. goods) the EU • Waste disposal
GHG
GHG GHG
Emissions
Emissions emissions
System
boundaries
for CBAM
embedded
Emissions
Raw materials Precursors
Waste
Products
under Product Carbon
consideration
Energy
Footprint (PCF)
consumption
Other products
other impacts beyond Full Product Toxicity and

Climate change/GHG Environmental other dangers
emissions Footprint (PEF)
Cradle to gate
Cradle to grave
6.1.4 Indirect emissions
For the purpose of the transitional period of the CBAM, indirect embedded emissions
have to be reported separately from the direct embedded emissions, for all goods
covered.
Indirect emissions of an installation or of a production process are equivalent to the

emissions caused by the production of the electricity consumed in the installation or
production process of goods, respectively, multiplied with the applicable emission factor
for electricity:
𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑚𝑚𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖 = 𝐸𝐸𝑚𝑚𝑒𝑒𝑒𝑒 = 𝐸𝐸𝑒𝑒𝑒𝑒 ∙ 𝐸𝐸𝐹𝐹𝑒𝑒𝑒𝑒 (Equations 49 and 44) 57
Where:
𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑚𝑚𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖 are the indirect attributed emissions of a production process expressed in t

CO2;
57
Note the Equation reference numbers given in this Guidance Document refer to Implementing
Regulation (EU) 2023/1773
70
𝐸𝐸𝑚𝑚𝑒𝑒𝑒𝑒 are the emissions related to electricity produced or consumed, expressed in t CO2;
𝐸𝐸𝑒𝑒𝑒𝑒 is the electricity consumed expressed in MWh or TJ; and
𝐸𝐸𝐹𝐹𝑒𝑒𝑒𝑒 is the emission factor for electricity applied, expressed in t CO2/MWh or t CO2/TJ.
The general rule for the emission factor is to use a default value provided by the European
Commission for that purpose. However, Annex IV section 6 defines conditions under
which actual data can be used for the emission factor:
• If there is a direct technical link between the installation in which the imported
good is produced and the electricity generation source; or
• If the operator of that installation has concluded a power purchase agreement with
a producer of electricity located in a third country for an amount of electricity that
is equivalent to the amount for which the use of a specific [emission factor] value
is claimed.
Therefore, if the operator generates electricity within their own installation, the emission
factor used for the calculation and reporting of indirect emissions may be determined
by the operator. If the operator receives electricity from a directly technically connected
installation and if that installation uses the same monitoring approaches as outlined in the
CBAM Implementing Regulation, the operator should use the emission factor provided by
that installation’s operator. Furthermore, if your installation has a power purchase
agreement 58 with an installation more remote, again the emission factor provided by that
electricity supplier should be used. In all other cases, i.e. for electricity received from the
grid, the default emission factor for electricity in the country or region as provided by
the European Commission shall be used. Those default values are based on data by the
IEA and are made accessible through the Commission’s CBAM Transitional Registry.
6.1.5 Adding precursor emissions
During the transitional period, standard values for the embedded emissions, as presented
in the Implementing Regulation, may be used where the precursor is a CBAM good.
Default values can be used to calculate the embedded emissions of precursor goods that
are used as inputs and consumed in the production process for other CBAM goods, where
the actual emissions intensities for these precursor goods are not available.
Default emission factors values have been calculated by the European Commission (for
both direct and indirect emissions where appropriate) by CN code. These are published on
the European Commission’s dedicated website for the CBAM:
• Default values given at a 4-digit CN code level apply to all goods falling within
this 4-digit CN code category (i.e. independent of the digits following these first 4
digits).
• Default values supplied at a 6-digit CN code level apply to all goods falling
within this 6-digit CN code category.
58
Annex IV to the CBAM Regulation defines: ‘power purchase agreement’ means a contract under which
a person agrees to purchase electricity directly from an electricity producer;
71
• Default values supplied at an 8-digit CN code level only apply to this specific 8-
digit CN code good – in most case these 8-digit codes are for the steel industry,
reflecting the range of different production routes and alloying elements used.
• In many cases the same default value applies to several CN codes.
Participants wishing to use the default values on the European Commission’s dedicated
CBAM website should note that these are set at a relatively high emissions intensity level
and, therefore, it may be more advantageous to use the actual values for precursor goods
where these are available.
6.1.6 Default emission factors for precursors
Default emissions factors may be used to calculate the embedded direct and indirect
emissions of precursor goods, where these precursor goods are used as inputs and are
consumed in the production process of other CBAM goods.
The factors are published on the European Commission’s dedicated CBAM website and
are listed by aggregated goods category, production route and relevant precursor. These
default values are separate direct and indirect specific embedded emissions (SEE) factors
(tCO2(e)/t good) for each precursor good.
Limits on the use of default values:
EU importers are allowed to use these values to ensure your compliance with the CBAM
requirements’, in case you do not receive relevant data in time from operators of
installations producing CBAM goods. They may be used:
• Without quantitative limit until 31 July 2024 i.e. for use in the first three
quarterly CBAM reports.
• Without time limit, but quantitatively limited: for complex goods, up to 20% of
the total embedded emissions may be determined using estimations. Using default
values provided by the Commission would qualify as ‘estimation’.
For reporting declarants, the default values can serve as a tool for you to check the
plausibility of the embedded emissions data provided by the operators, as the default values
are determined as global average values based on publicly available sources. If the values
reported by the operator are substantially different from the default values, then it is
recommended you check with the operator that there is no error in the data or calculation
of the embedded emissions.
Default emission factors for grid electricity
Where grid electricity is consumed by a production process, you may use a default value
based on either:
• The average emission factor for grid electricity (in the electricity’s country of
origin), based on data from the International Energy Agency (IEA) provided by
the European Commission in the CBAM Transitional Registry; or
72
• Any other emission factor of the country of origin’s electricity grid based on
publicly available data representing either the average emission factor 59 or the
CO2 emission factor
You should note that the determination of specific emissions factors by using market-based
instruments such as “guarantees of origin” or “green certificates” etc. are not allowed.
6.2 Reporting requirements
This section outlines how you should report production and embedded emissions during
the CBAM transitional period. The textbox below signposts the key sections in the
Implementing Regulation for reporting, relevant for the CBAM transitional period.
Annex II, Section 1 Definitions.
Annex III, Section F Rules for attributing emissions from an installation to goods.
Annex III, Section I Communication by the operator of the data for the use by the reporting declarant in
the CBAM report.
Default values for the calculation of embedded emissions, provided by the European Commission and
published on their dedicated website for the CBAM.
6.2.1 Reporting the quantity of goods imported
In a given reporting period, the total quantity of goods imported that meets a particular CN
product specification for that good is to be reported, and expressed in tonnes or MWh for
electricity.
6.2.2 Reporting the quality of certain goods imported
There are some additional qualifying parameters that you as the EU importer needs to
report under the CBAM. These depend on the goods imported. For example, for cements
imported, the total clinker content needs to be reported, for mixed fertilizers the contents
of the different forms of nitrogen, etc. The relevant parameters are listed in section 2 of
Annex IV of the Implementing Regulation.
You need to ensure that you collect all the parameters necessary for your CBAM goods
from the producer(s) of the imported good(s).
These additional reporting requirements are listed for each sector in section 5. Some of
these parameters require quality information of the products such as, for example, the
clinker content of cement, the content of certain alloy elements in steel, the amount of
59
The CBAM Regulation defines: ‘Emission factor for electricity’ means the default value, expressed in
CO2e, representing the emission intensity of electricity consumed in production of goods.
73
scrap used for the production of steel and aluminium, the concentration of nitric acid or of
hydrous ammonia, or the content of different nitrogen forms in mixed fertilizers.
As a general rule, producers may use the annual average of the quality measure for the
whole production process for reporting purposes under the same CN code. Optionally, if
the operator has more detailed monitoring possibilities, a “per product” monitoring is
encouraged.
Note that the potential for differentiation of goods by their quality allows importers the
opportunity to report data on a more detailed level than just CN codes. For example, if you
import three different grades of mixed fertilizers, you could report these as three separate
goods with the same CN code with different embedded emissions and composition data.
6.2.3 Reporting direct and indirect embedded emissions
During the transitional period you need to account for both ‘direct emissions’ 60 and
‘indirect emissions’ 61, in reporting the embedded emissions of the goods imported.
Where several production routes have been used for producing goods falling under the
same CN code, and those production routes are assigned to different production processes,
the embedded emissions of the goods are calculated and reported separately for each
production route.
Embedded emissions in precursor goods
The operator should include the embedded emissions in precursor goods (both direct and
indirect emissions) in the calculation of total embedded emissions for a final good, making
this a ‘complex good’. The embedded emissions of the relevant precursor goods 62 are
added to embedded emissions of the complex good.
The inclusion of embedded emissions of precursor goods is necessary to ensure

comparability of carbon costs under the EU ETS and the CBAM. The relevant greenhouse
gas emissions correspond to those greenhouse gas 63 emissions covered also by Annex I to
the EU ETS Directive 2003/87/EC, namely 64 carbon dioxide (CO2) for all sectors, and
additionally nitrous oxide (N2O) for some fertilizer goods and perfluorocarbons (PFCs) for
some aluminium goods.
60
‘direct emissions’ mean emissions from the production processes of goods including emissions from the
production of heating and cooling consumed during the production processes, regardless of the location
of the production of the heating and cooling;
61
‘indirect emissions’ mean emissions from the production of electricity, which is consumed during the
production processes of goods, regardless of the location of the production of the consumed electricity.
62
Where a precursor is itself a complex good, this process is repeated recursively until no more precursors
are relevant.
63
‘greenhouse gases’ mean greenhouse gases as specified in Annex I in relation to each of the goods listed
in that Annex;
64
The CBAM Regulation, paragraph 17
74
6.2.4 Units for reporting embedded emissions
The unit used for reporting embedded greenhouse gas is ‘tonne of CO2e 65’, which means
one metric tonne of carbon dioxide (‘CO2’), or an amount of any other greenhouse gas
listed in Annex I with an equivalent (‘e’) global warming potential; i.e. where relevant,
N2O and PFCs emissions should be converted to their ‘tCO2e’ value.
For reporting purposes embedded emissions data should be rounded to whole tonnes CO2e
over the reporting period. Parameters used to calculate the reported embedded emissions
should be rounded to include all significant digits, to a maximum of 5 decimal places. The
level of rounding required for parameters used in such calculations will depend on the
accuracy and precision of the measurement equipment used.
6.2.5 Reporting the effective carbon price due
In order to ensure the fair treatment of goods produced in different installations in different
jurisdictions, it is necessary for the importer to report the ‘effective carbon price due66
for production of the CBAM goods. This may be applied at a national or subnational level.
The ‘effective carbon price’ is the actual price per tonne CO2e due and should take into
account:
• The actual price of a tonne CO2e in the carbon pricing scheme in the jurisdiction;
• The coverage of emissions of the production processes in the carbon pricing
scheme (direct, indirect, types of GHG, etc.);
• Any applicable ‘rebates’ 67, i.e. the amount of free allocation (in the case of an
ETS) or any financial support, compensation or other form of rebate received in
that jurisdiction, per tonne of the product relevant for the CBAM; and
• In the case of complex goods, the carbon price due (after any rebates received) of
any relevant precursor materials consumed in the production process.
In the transitional period this is a reporting obligation for importers; however, in the
definitive period disclosure of this information will give importers a rebate in the amount
otherwise due to be paid by the person liable for the CBAM obligation.
The total carbon price due needs to be attributed to the CBAM goods in a similar way as
the specific embedded emissions.
65
‘tonne of CO2e’ means one metric tonne of carbon dioxide (‘CO2’), or an amount of any other
greenhouse gas listed in Annex I with an equivalent global warming potential
66
The CBAM Regulation defines: ‘carbon price’ means the monetary amount paid in a third country,
under a carbon emissions reduction scheme, in the form of a tax, levy or fee or in the form of emission
allowances under a greenhouse gas emissions trading system, calculated on greenhouse gases covered
by such a measure, and released during the production of good.
67
The Implementing Regulation defines: ‘rebate’ means any amount that reduces the amount due or paid
by a person liable for the payment of a carbon price, before its payment or after, in a monetary form or
in any other form.
75
The carbon price due may be attributed to a production process and aggregated good
category in a similar way to how specific embedded emissions are calculated, and should
be expressed as euros per tonne of CBAM good.
For complex goods, where relevant precursors are consumed by the production process,
the carbon price due by the supplier should be added to that determined for the complex
CBAM good, and the resulting carbon price calculated.
If the supplier of the precursor does not provide the required information, you have to
assume the carbon price due for the precursor to be zero.
The two main types of carbon pricing system in operation are an emissions trading system
(ETS) or a carbon price in the form of a tax, levy or fee. In these cases the type of
information that operators should report are as follows:
• Carbon price under an Emission Trading System (ETS):

o The annual average price of allowances/certificates relating to one metric
tonne of CO2e in the applicable currency;
o Details of the ETS rules 68, such as whether it applies to direct and/or
indirect emissions;
o The total emissions for which you had to surrender allowances or
certificates;
o The total number of allowances or certificates which you received for
free, as a ‘free allocation’;
o The resulting difference between emissions and free allocation. If the
latter exceeds the emissions, the carbon price due is to be reported as zero.
• Carbon price in the form of a tax, levy or fee:
o The annual average amount of tax, levy or fee relating to one metric tonne
of CO2e in the applicable currency. If the amount is different e.g. for
different fuels used, a weighted average rate corresponding to the fuel mix
of your installation is to be determined for each reporting period;
o Details on the rules applicable68 to the tax, levy or fee, such as whether it
applies to direct and/or indirect emissions or specific processes or fuels,
etc.;
o The total emissions for which you had to pay the carbon price under the
tax, levy or fee;
o Any rebate you were allowed to apply to your payment of the carbon tax,
levy or fee;
o The resulting total carbon tax paid. If the rebate exceeds the tax rate
before the application of the rebate (or refunding), the carbon price due is
to be reported as zero.
68
Importers will have to provide a description and indication of legal act – i.e. provide the regulation
reference, ideally as internet link. Therefore, you should also provide this information.
76
Other types of carbon price system may be possible, such as Results-Based Climate
Finance (RBCF) but these are not typical of industry sectors, and are not eligible under the
CBAM legislation.
The exchange rate between the applicable currency of the carbon price due and euros will
be applied automatically in the CBAM Transitional Registry when the CBAM Report is
entered by the reporting declarant, using the average yearly exchange rate for the preceding
year.
6.2.6 Information relevant for importers
During the transitional period importers report details of both the carbon price due (i.e.
the carbon price in the country of origin) and also the CBAM products covered by the
carbon price, although the specific details to be reported will vary according to the type
of carbon pricing system in operation (ETS, carbon tax, levy or fee, or other, as above).
The details that should be reported on are summarised in the table below.
Table 6-1: Reporting the carbon price due
Quarterly report Detailed information required

category
Carbon price due – Emissions sequence number (per CBAM Transitional
Registry).
– Type of carbon price (e.g. ETS or carbon price in the form

of a tax, levy or fee), rebate received (which for an ETS may
be free allocation) or any other form of compensation (such
as a reduced rate of taxation for energy intensive industry).
– Description and indication of legal act - i.e. provide a

description of the carbon pricing regulation that establishes
the ETS system or carbon tax, levy or fee in the country of
origin, and provide the regulation reference.
– Amount of carbon price due - in the currency of the country

of origin where the carbon price is due. This is converted
into a euro equivalent, using the average yearly exchange
rate for the preceding year.
– Details of the currency in the country of origin and

applicable exchange rate (see below).
Products covered by – Emissions Sequence number (per CBAM Transitional

carbon price due Registry).
– Type of product covered and the corresponding CN code –

the carbon price due should be separately listed for
precursors obtained from other installations.
– Quantity of emissions covered – embedded direct or indirect

emissions.
77
– Quantity of emissions covered by any rebate or other form
of compensation.
– Any supplementary or additional information as required by

the CBAM Transitional Registry.
The amount of carbon price due in the currency of the country of origin should be
converted to the euro equivalent, using the average yearly exchange rate for the preceding
year to the year in which the report is due; the factor is provided in the CBAM Transitional
Registry and in most cases is the yearly conversion factor published by the European
Central Bank.
6.3 Reporting template
During the transitional period reporting declarants need submit quarterly reports on the
CBAM Transitional Registry. The report structure is given in Annex I to the Implementing
Regulation. To complete the report on the Transitional Registry, you, as a reporting
declarant, need to obtain information on the embedded emissions of imported goods from
the operators of the installations making these goods for export.
6.3.1 Emission data communication from operators
Information on embedded emissions may be provided by operators to reporting declarants

using an ‘emissions data communication’ template report, which has been developed by
the European Commissions and which is given in Annex IV of the Implementing
Regulation. The use of this template is not obligatory but can greatly facilitate the
information exchange.
The template is divided into two parts: the first part of the template contains all necessary
embedded emissions information that you, as the reporting declarant, need to compile for
your CBAM report; the second part of the template is an optional section that operators are
recommended to complete, as it will provide greater transparency of the data reported
under Part 1.
Reporting declarants may use the information in Part 2 to carry out their own data quality
checks on the contents of Part 1.
The contents of the operator’s emissions communication is outlined in the table below for
your information.
Table 6-2: Contents of the operator’s emissions data communication to reporting declarants
Template Summary of information required for the transitional period

Part 1 – Includes the data to be communicated to the reporting declarant.
General
information – Installation data, comprising identification and location details for
the operator’s installation, and contact details for the operator’s
authorised representative.
78
– The production processes and routes under each aggregated goods
category at the installation.
– For each aggregated goods category or separately for each good by

CN code:
– The direct and indirect specific embedded emissions of each

good; and for SEE indirect detail on how the emission factor
was determined and the information source used;
– Information on what data quality and methods (calculation-

based, measurement-based, other) were used for determining
embedded emissions, and whether this was based fully on
monitoring, or if default values were used;
– If default values were used, a short description why these were

used instead of actual data;
– Information on additional sector-specific reporting parameters

for goods produced, if required; and
– If applicable, information on a carbon price due, and separately

for any precursors obtained from other installations, by the
precursors’ country of origin.
Part 2 – Provides greater transparency of the data under Part 1, and

Optional allows the reporting declarant to carry out validation checks
information on Part 1.
– The total emissions of the installation, including: activity data and

calculation factors for each source stream used; emissions of each
emission source monitored using a measurement-based
methodology, and emissions determined by other methods; and if
applicable, any CO2 imports or exports to other installations, for
the reasons outlined above.
– A ‘heat balance’ of imported, produced, consumed and exported

measurable heat, and similarly balances for waste gases or
electricity.
– A list of all relevant goods by CN code produced by the

installation, including precursors not covered by separate
production processes.
– For precursor goods:
– The quantity received from elsewhere.
– Their specific direct and indirect embedded emissions (as

reported by other operators).
79
– The quantity used in each production process, excluding
precursor goods produced in the same installation.
– For attributed direct and indirect emissions: information on how

the attributed emissions of each production process were
calculated; the activity level and attributed emissions of each
production process.
– A short description of the installation, covering: relevant and non-

relevant (out of scope) production processes;
– The main production processes taking place at the installation

and any production processes not covered for CBAM purposes;
– The main elements of the monitoring methodology being used;

and
– What measures to improve data quality have been taken, in

particular whether any form of verification (in the definitive
period) was applied.
– information on the electricity emissions factor in the power

purchase agreement, where appropriate.
Source: Annex IV to the Implementing Regulation.
To help operators share their information on embedded emissions with you, as a reporting
declarant, the template in Annex IV has been translated into a ‘voluntary to use’
spreadsheet, providing the information under Parts 1 and 2 in the table above. The
following Figure 6-2 shows how this spreadsheet template is structured.
80
Figure 6-2: Voluntary electronic data communication template – Contents page
Key features of the template include:
• User-friendly navigation and automatic calculation of CBAM embedded

emissions data from data inputs, showing how attributed emissions have been
calculated for each production process.
• Covers information for both Parts 1 and 2 in the operators’ report above,
identifies what data is required for the reporting declarants to complete the
CBAM report and what data is optional, and provides guidance on how to use the
template and on the different calculations performed.
• Tools for facilitating reporting, for attributing emissions between heat and
electricity for CHP/cogeneration and for calculating the carbon price due.
• Summary sheets providing the main information on production processes and
products to be communicated to the reporting declarant for their CBAM Reports.
The spreadsheet is available from the European Commission’s dedicated website for the
CBAM.
81
6.3.2 Reporting by declarants
The contents and reporting structure of the CBAM report that reporting declarants must
complete is indicated in Annex I of the Implementing Regulation ‘Information to be
submitted in the CBAM reports’. The CBAM report has been digitally integrated into the
Transitional Registry, as summarised in the table below.
Table 6-3: Contents of the CBAM report in the Transitional Registry
Registry Summary of the contents of the CBAM report in Annex I

CBAM report
structure
Section 1 - – Report issue date, ID, reporting period and year.
Header
– Total quantity of goods imported and total emissions.
– Identity and contact details of Reporting declarant, Representative,

Importer and Competent Authority, as applicable.
– Approval process for report submission.
Section 2 - – Description of goods including details of commodity codes.

CBAM goods
imported – Procedures for imported goods including for inward processing.
– Quantities of imported goods and corresponding emissions.
– Supporting documentation for goods that may be uploaded to the

Registry, and additional information as applicable.
Section 3 - – Details of the installation, including name, location and contact

CBAM goods details.
emissions
– Details of goods produced, by reporting methodology.
– Details of installation direct, indirect and total embedded emissions,

quantity of emissions and related qualifying parameters.
– Details of carbon price due and product and corresponding

emissions coverage.
Information on the embedded emissions of goods from operators is used to complete

Section 3 of the CBAM report, and also feeds into Section 2. The mapping of key
information between the reporting declarant’s CBAM report and the operator’s emissions
communication spreadsheet is given in the table below.
82
Table 6-4: Mapping the CBAM report in the Registry to the operator’s emissions communication
spreadsheet
Transitional Annex I to the Implementing Voluntary Emissions communications

Registry Regulation – CBAM Report for spreadsheet
CBAM declarants
report
Section Report structure Sheet reference for data from operator
CBAM --CBAM goods imported
Goods
Imported
----Representative
----Importer
----Commodity code
Harmonized System sub-heading code Sheet "Summary_Communication”
Combined nomenclature code Sheet "Summary_Communication”
------Commodity details
Description of goods Sheet "Summary_Communication”
----Country of origin
Country code Sheet "Summary_Communication”
-----Imported quantity per customs
procedure
------Procedure
Inward processing information
------Area of import
------Goods measure (per
procedure)
------Special references for goods
----Goods measure (imported)
----Goods imported total emissions
----Supporting documents (for
Goods)
------Attachments
----Remarks
CBAM ----CBAM Goods Emissions ----CBAM Goods Emissions
Goods
Emissions
Country of production Sheet "Summary_Communication”
------The company name of the
installation
--------Address
--------Contact Details
Name Sheet "A_InstData"
Phone number Sheet "A_InstData"
e-mail Sheet "A_InstData"
------Installation
Installation name Sheet "Summary_Communication”
Economic activity Sheet "Summary_Communication”
--------Address
Country of establishment Sheet "A_InstData"
83
CBAM declarants
report
City Sheet "A_InstData"
Street Sheet "A_InstData"
Number Sheet "A_InstData"
Postcode Sheet "A_InstData"
P.O. Box Sheet "A_InstData"
UNLOCODE Sheet "Summary_Communication" &
Latitude Sheet "Summary_Communication"
Longitude Sheet "Summary_Communication"
Type of co-ordinates Sheet "Summary_Communication"
------Goods measure (Produced)
Net mass Sheet "D_Processes"
Supplementary units Sheet "D_Processes"
Type of measurement unit Sheet "D_Processes"
------Installation emissions
Installation total emissions Sheet "Summary_Communication"
Installation direct emissions Sheet "Summary_Communication"
Installation indirect emissions Sheet "Summary_Communication"
Type of measurement unit for Sheet "Summary_Communication"
emissions
------Direct Embedded Emissions
Type of determination Sheet "B_Emlnst" &
"C_Emissions&Energy"
Type of applicable reporting Sheet "B_Emlnst" &
methodology "C_Emissions&Energy"
Applicable reporting methodology Sheet "Summary_Communication"
Specific (direct) embedded emissions Sheet "Summary_Communication"
Electricity imported Sheet “D_Processes"
Total embedded emissions of Sheet "Summary_Communication"
electricity imported
Type of measurement unit Sheet "Summary_Communication"
Source of emissions factor value Sheet "Summary_Communication"
------Indirect Embedded Emissions
Type of determination Sheet "D_Processes"
Source of emission factor Sheet "Summary_Communication"
Emission factor Sheet "D_Processes"
Specific (indirect) embedded Sheet "Summary_Communication"
emissions
Type of measurement unit Sheet "Summary_Communication"
Electricity consumed Sheet "Summary_Communication"
------Production method & Qualifying
parameters
Method name Sheet "Summary_Communication"
Identification number of the specific Sheet "Summary_Communication"
steel mill
Additional Information Sheet "Summary_Communication"
--------Direct Emissions qualifying
parameters
84
CBAM declarants
report
--------Indirect Emissions qualifying
parameters
------Supporting Documents (for
emissions definition)
--------Attachments
------Carbon price due
Type of carbon price, rebate or any Sheet "Summary_Communication"
other form of compensation
Amount of carbon price due Sheet "Summary_Communication"
Currency Sheet "Summary_Communication"
Country code Sheet "Summary_Communication"
--------Products covered under carbon
price due
Type of product covered Sheet "Summary_Communication"
CN of goods covered Sheet "Summary_Communication"
Quantity of emissions covered Sheet "Summary_Communication" &
Sheet "F_Tools"
Quantity covered by any rebate or Sheet "Summary_Communication"
other form of compensation
----------Goods measure (Covered)
------Remarks
The information required to complete the CBAM report is mostly found in the
‘Summary_Communication’ sheet at the back of the operator’s emissions communication
spreadsheet.
Figure 6-3: Summary Communication sheet, voluntary electronic data communication template
Relevant parameters calculated for reporting purposes in these summary sheet include:
• Amount of carbon price due
• Electricity consumed
• Specific (direct) embedded emissions
• Specific (indirect) embedded emissions
85
• Additional sector-specific reporting parameters e.g. % alloy content, tonnes scrap
/ tonne of aluminium or steel, % pre-consumer scrap, concentration, nitrogen
content etc.
Although the spreadsheet is voluntary to use, reporting declarants can request that
operators provide their emissions communication using this template.
86
7 EXEMPTIONS FROM THE CBAM
During the transitional period certain general exemptions apply, which are listed below.

• The CBAM Regulation (EU) 2023/956, Section I, Article 2 Scope, paragraphs 3, 4 and 7; Annex III
Third countries and territories outside the scope of this Regulation for the purpose of Article 2.
De minimis exemption
Small quantities (de minimis) of imported goods that are in scope for the CBAM may be
automatically treated as exempt from the provisions of the CBAM legislation, provided
that the value of these goods is negligible, that is to say does not exceed EUR 150 per
consignment 69. This exemption also applies during the transitional phase.
Military use exemption 70
An exemption applies to any goods imported to be used by the military authorities of

Member States, or under agreement with those of a non-EU country, under the EU’s
Common Security and Defence Policy, or under NATO.
EFTA exemption
Countries which apply the EU ETS (Norway, Iceland, Liechtenstein), or which have an
ETS fully linked to the EU ETS (Switzerland), are exempted from the CBAM.
Countries exempted for all CBAM goods are listed in Annex III, section 1 of the CBAM
Regulation; countries exempted for electricity would be added to section 2 of that Annex,
which is currently empty.
Limited exemption for electricity imports
Imports of electricty from non-EU countries are covered by the CBAM, unless the non-
EU country is so closely integrated with the EU internal market for electricity that a
technical solution to apply the CBAM to these imports cannot be found; this exemption
only applies in limited circumstances only and is subject to the conditions outlined in
Article 2 of the CBAM Regulation.
69
Article 23 of Council Regulation (EC) No 1186/2009. See: https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:324:0023:0057:EN:PDF
70
Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No
952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain
provisions of the Union Customs Code.
87
Annex A List of abbreviations
Abbreviation Full term

AD Activity Data
AEM Anode Effect Minutes
AEO Anode Effect Overvoltage
AL Activity Level
AOD Argon Oxygen Decarburisation.
BAT Best Available Techniques
BF Biomass Fraction
BFG Blast Furnace Gas
BOF Basic Oxygen Furnace
BOFG Basic Oxygen Furnace Gas
BREFs Best Available Techniques reference documents
CA Competent Authority
CBAM Carbon Border Adjustment Mechanism
CCR Clinker to Cement Ratio
CCS Carbon Capture and Storage
CCU Carbon Capture and Utilisation
CCUS Carbon Capture, Utilisation and Storage
CEMS Continuous Emission Measurement Systems
CF Conversion Factor
CFP Carbon footprint of products
CHP Combined Heat and Power
CKD Cement Kiln Dust
CN Combined nomenclature
COG Coke Oven Gas
DRI Direct Reduction Iron
EAF Electric Arc Furnace
EF Emission Factor
EFTA European Free Trade Area
ETS Emissions Trading System
EU ETS EU Emissions Trading System
EUA EU Allowances (used in the EU ETS)
EUR Euro (currency)
88
Abbreviation Full term
FAR Free Allocation Rules (Regulation 2019/331) 71
GHG Greenhouse Gas
GWP Global Warming Potential
HBI Hot Briquetted Iron
HS Harmonised System (for international trade)
IEA International Energy Agency
ISO International Organization for Standardization
LULUCF Land-use, land change and forestry (criteria)
MMD Monitoring Methodology Documentation
MRR Monitoring and Reporting Regulation (Regulation 2018/2066) 72
MRV Monitoring, Reporting and Verification
MS Member State(s)
MWh Megawatt-hour
NCV Net Calorific Value
NPI Nickel pig iron
OF Oxidation Factor
PCI Pulverised Coal Injection
PEMS Predictive Emission Monitoring System
PFC Perfluoro-carbon
SEE Specific embedded emissions
TARIC Integrated Tariff of the European Union database
TJ Terajoules
TSO Transmission System Operator
UCC Union Custom Code
UN/LOCODE United Nations Code for Trade and Transport Location
71
Free Allocation Rules (Commission Delegated Regulation (EU) 2019/331 of 19 December 2018
determining transitional Union-wide rules for harmonised free allocation of emission allowances
pursuant to Article 10a of Directive 2003/87/EC of the European Parliament and of the Council)
72
Monitoring and Reporting Regulation (Commission Implementing Regulation (EU) 2018/2066 of 19
December 2018 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive
2003/87/EC of the European Parliament and of the Council and amending Commission Regulation (EU)
No 601/2012
89
Annex B List of definitions
Term Definition
‘Accuracy’ means the closeness of the agreement between the result of
a measurement and the true value of the particular quantity
or a reference value determined empirically using
internationally accepted and traceable calibration materials
and standard methods, taking into account both random
and systematic factors;
‘Activity data’ means the amount of fuels or materials consumed or
produced by a process relevant for the calculation-based
methodology, expressed in terajoules (TJ), mass in tonnes
or (for gases) volume in normal cubic metres, as
appropriate
‘Actual emissions’ means the emissions calculated based on primary data from
the production processes of goods and from the production
of electricity consumed during those processes as
determined in accordance with the methods set out in
Annex IV [of the Implementing Regulation Annexes]
‘Activity level’ means the quantity of goods produced (expressed in MWh
for electricity, or in tonnes for other goods) within the
boundaries of a production process
‘Agricultural, means residues that are directly generated by agriculture,
aquaculture, fisheries aquaculture, fisheries and forestry and that do not include
and forestry residues’ residues from related industries or processing
‘Authorised CBAM means a person authorised by the competent authority in
declarant’ accordance with Article 17 of the CBAM Regulation (EU)
2023/956
‘Batch’ means an amount of fuel or material representatively
sampled and characterised, and transferred as one shipment
or continuously over a specific period of time
‘Biomass’ means 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
‘Calculation factors’ means net calorific value, emission factor, preliminary
emission factor, oxidation factor, conversion factor, carbon
content or biomass fraction
‘Carbon price’ means the monetary amount due in a third country, under a
carbon emissions reduction scheme, in the form of a tax,
levy or fee or in the form of emission allowances under a
greenhouse gas emissions trading system, calculated on
greenhouse gases covered by such a measure, and released
during the production of goods
90
Term Definition
‘CBAM certificate’ means a certificate in electronic format corresponding to
one tonne of CO2e of embedded emissions in goods
‘CO2 emission factor’ means the weighted average of the CO2 intensity of
electricity produced from fossil fuels within a geographic
area. The CO2 emission factor is the result of the division of
the CO2 emission data of the electricity sector by the gross
electricity generation based on fossil fuels in the relevant
geographic area. It is expressed in tonnes of CO2 per
megawatt-hour
‘Combined means the classification of goods, designed to meet the
nomenclature’ (CN) needs of: i) the Common customs tariff, setting import
duties for products imported into the European Union (EU),
as well as the Integrated tariff of the European
Communities (Taric), incorporating all EU and trade
measures applied to goods imported into and exported out
of the EU; ii) the international trade statistics of the EU.
The CN provides the means of collecting, exchanging and
publishing data on EU international trade statistics. It is
also used for the collection and publication of international
trade statistics in intra-EU trade. 73
‘Combustion means greenhouse gas emissions occurring during the
emissions’ exothermic reaction of a fuel with oxygen
‘Competent means the authority designated by each Member State in
authority’ accordance with Article 11 of the CBAM Regulation (EU)
2023/956
‘Continuous emission means a set of operations having the objective of
measurement’ (CEM) determining the value of a quantity by means of periodic
measurements, applying either measurements in the stack
or extractive procedures with a measuring instrument
located close to the stack, whilst excluding measurement
methodologies based on the collection of individual
samples from the stack
‘Complex goods’ means goods other than simple goods
‘Conservative’ means that a set of assumptions is defined in order to
ensure that no under-estimation of reported emissions or
over-estimation of production of heat, electricity or goods
occurs
‘Conversion factor’ means the ratio of carbon emitted as CO2 to the total carbon
contained in the source stream before the emitting process
takes place, expressed as a fraction, considering CO emitted
to the atmosphere as the molar equivalent amount of CO2
73
For definition see: https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Glossary:Combined_nomenclature_(CN)
91
Term Definition
‘Customs declarant’ means the declarant as defined in Article 5(15) of
Regulation (EU) No 952/2013 lodging a customs
declaration for release for free circulation of goods in its
own name or the person in whose name such a declaration
is lodged
‘CCUS system’ means a group of economic operators with technically
connected installations and transport equipment for CO2
capture, transport, use in production of goods, or geological
storage
‘Data flow activities’ mean activities related to the acquisition, processing and
handling of data that are needed to draft an emissions report
from primary source data
‘Data set’ means one type of data, either at installation level or
production process level as relevant in the circumstances,
as any of the following:
(a) the amount of fuels or materials consumed or
produced by a production process as relevant for the
calculation-based methodology, expressed in terajoules,
mass in tonnes, or for gases as volume in normal cubic
metres, as appropriate, including for waste gases;
(b) a calculation factor;
(c) net quantity of measurable heat, and the relevant
parameters required for determining this quantity, in
particular: i) mass flow of heat transfer medium; and ii)
enthalpy of transmitted and returned heat transfer medium,
as specified by composition, temperature, pressure and
saturation;
(d) quantities of non-measurable heat, specified by the
relevant quantities of fuels used for producing the heat, and
the net calorific value (NCV) of the fuel mix;
(e) quantities of electricity;
(f) quantities of CO2 transferred between installations;
(g) quantities of precursors received from outside the
installation, and their relevant parameters, such as country
of origin, used production route, specific direct and
indirect emissions, carbon price due;
(h) parameters relevant for a carbon price due
‘Default value’ means a value, which is calculated or drawn from
secondary data, which represents the embedded emissions
in goods
‘Direct emissions’ means emissions from the production processes of goods
including emissions from the production of heating and
cooling that is consumed during the production processes,
irrespective of the location of the production of the heating
and cooling
92
Term Definition
‘Eligible monitoring, means the MRV systems where the installation is
reporting and established 74 for the purpose of a ‘carbon pricing scheme’,
verification (MRV) or compulsory emission monitoring schemes, or an
system’ emission monitoring scheme at the installation which can
include verification by an accredited verifier, in accordance
with Article 4(2) of the CBAM Implementing Regulation
‘Embedded emissions’ means direct emissions released during the production of
goods and indirect emissions from the production of
electricity that is consumed during the production
processes, calculated in accordance with the methods set
out in Annex IV and further specified in the Implementing
Regulations adopted pursuant to Article 7(7)
‘Emissions’ mean the release of greenhouse gases into the atmosphere
from the production of goods
‘Emission factor’ means the average emission rate of a greenhouse gas
relative to the activity data of a source stream assuming
complete oxidation for combustion and complete
conversion for all other chemical reactions
‘Emission factor’ for means the default value, expressed in CO2e, representing
electricity the emission intensity of electricity consumed in production
of goods.
‘Emission source’ means a separately identifiable part of an installation or a
process within an installation, from which relevant
greenhouse gases are emitted
EU ETS means the system for greenhouse gas emissions allowance
trading within the Union in respect of activities listed in
Annex I to Directive 2003/87/EC other than aviation
activities
‘Fossil carbon’ means inorganic and organic carbon that is not biomass
‘Fossil fraction’ means the ratio of fossil and inorganic carbon to the total
carbon content of a fuel or material, expressed as a fraction
‘Fugitive emissions’ means irregular or unintended emissions from sources that
are not localised, or too diverse or too small to be
monitored individually
‘Goods’ means goods listed in Annex I to the CBAM Regulation
(EU) 2023/956 [and Annex II to the Implementing
Regulations]
‘Greenhouse gases’ mean greenhouse gases as specified in Annex I of the
CBAM Regulation (EU) 2023/956 [and Annex II of the
Implementing Regulation Annexes] in relation to each of
the goods listed in that Annex
74
Refers to the jurisdiction in which the installation is located.
93
Term Definition
‘Importer’ means either the person lodging a customs declaration for
release for free circulation of goods in its own name and on
its own behalf or, where the customs declaration is lodged
by an indirect customs representative in accordance with
Article 18 of Regulation (EU) No 952/2013, the person on
whose behalf such a declaration is lodged
‘Importation’ means release for free circulation as provided for in Article
201 of Regulation (EU) No 952/2013
‘Indirect emissions’ means emissions from the production of electricity, which
is consumed during the production processes of goods,
regardless of the location of the production of the
consumed electricity.
‘Inherent CO2’ means CO2 which is part of a source stream.
‘Installation’ means a stationary technical unit where a production
process is carried out
‘Measurable heat’ means a net heat flow transported through identifiable
pipelines or ducts using a heat transfer medium, such as, in
particular, steam, hot air, water, oil, liquid metals and salts,
for which a heat meter is or could be installed
‘Measurement point’ means the emission source for which continuous emission
measurement systems (CEMS) are used for emission
measurement, or the cross-section of a pipeline system for
which the CO2 flow is determined using continuous
measurement systems
‘Measurement means a complete set of measuring instruments and other
system’ equipment, such as sampling and data processing
equipment, used to determine variables such as the activity
data, the carbon content, the calorific value or the emission
factor of the greenhouse gas emissions
‘Minimum means monitoring methods using the minimum efforts
requirements’ allowed for determining data in order to result in emission
data acceptable for the purpose of Regulation (EU)
2023/956.
‘Mixed fuel’ means a fuel which contains both biomass and fossil carbon
‘Mixed material’ means a material which contains both biomass and fossil
carbon
‘Net calorific value’ means the specific amount of energy released as heat when
(NCV) a fuel or material undergoes complete combustion with
oxygen under standard conditions, less the heat of
vaporisation of any water formed
‘Non-measurable means all heat other than measurable heat
heat’
‘Operator’ means any person who operates or controls an installation
in a third (i.e. non-EU) country
94
Term Definition
‘Power purchase means a contract under which a person agrees to purchase
agreement’ electricity directly from an electricity producer
‘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 Table 1 of Section
2 of Annex II, and its specified system boundaries
regarding inputs, outputs and corresponding emissions
‘Production route’ 75 means a specific technology used in a production process
to produce goods under an aggregated goods category
‘Process emissions’ means greenhouse gas emissions other than combustion
emissions occurring as a result of intentional and
unintentional reactions between substances or their
transformation, for a primary purpose other than the
generation of heat, including from the following 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.
‘Proxy data’ means annual values which are empirically substantiated or
derived from accepted sources and which an operator uses
to substitute a data set 76 for the purpose of ensuring
complete reporting when it is not possible to generate all
the required data or factors in the applicable monitoring
methodology
‘Rebate’ means any amount that reduces the amount due or paid by a
person liable for the payment of a carbon price, before its
payment or after, in a monetary form or in any other form.
‘Recommended means monitoring methods which are proven means to
improvements’ ensure that data are more accurate or less prone to mistakes
than by mere application of minimum requirements, and
which may be chosen on a voluntary basis
‘Reporting declarant’ means any of the following persons:
(a) the importer who lodges a customs declaration for
release for free circulation of goods in its own name and on
its own behalf;
75
Note that different production routes can fall within the same production process.
76
Refers to the activity data or the calculation factors.
95
Term Definition
(b) the importerperson, holding an authorisation to
lodge a customs declaration referred to in Article 182(1) of
Regulation (EU) No 952/2013, who declares the
importation of goods;
(c) the indirect customs representative, where the
customs declaration is lodged by the indirect customs
representative appointed in accordance with Article 18 of
Regulation (EU) No 952/2013, when the importer is
established outside the Union or where the indirect customs
representative has agreed to the reporting obligations in
accordance with Article 32 of Regulation (EU) 2023/956.
‘Reporting period’ means a period that the operator of an installation has
chosen to use as reference for the determination of
embedded emissions
‘Residue’ means a substance that is not the end product(s) that a
production process directly seeks to produce; it is not a
primary aim of the production process and the process has
not been deliberately modified to produce it
‘Recommended means monitoring approaches which are proven means to
improvements’ ensure that data are more accurate or less prone to mistakes
than by mere application of minimum requirements, and
which may be chosen on a voluntary basis
‘Simple goods’ means goods produced in a production process requiring
exclusively input materials and fuels having zero embedded
emissions
‘Source stream’ means any of the following: (a) a specific fuel type, raw
material or product giving rise to emissions of relevant
greenhouse gases at one or more emission sources as a
result of its consumption or production; (b) a specific fuel
type, raw material or product containing carbon and
included in the calculation of greenhouse gas emissions
using a mass-balance method
‘Specific embedded means the embedded emissions of one tonne of goods,
emissions’ expressed as tonnes of CO2e emissions per tonne of goods
‘Third country’ means a country or territory outside the customs territory of
the European Union
‘Tonne of CO2(e)’ means one metric tonne of carbon dioxide (‘CO2’), or an
amount of any other greenhouse gas listed in Annex I with
an equivalent global warming potential (‘CO2e‘)
‘Transmission system means an operator as defined in Article 2(35) of Directive
operator’ (EU) 2019/944 of the European Parliament and of
the Council ( 77).
77
Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common
rules for the internal market for electricity and amending Directive 2012/27/EU (OJ L 158, 14.6.2019,
p. 125).
96
Term Definition
‘Waste’ means any substance or object which the holder discards or
intends or is required to discard, excluding substances that
have been intentionally modified or contaminated in order
to meet this definition
‘Waste gas’ means a gas containing incompletely oxidised carbon in a
gaseous state under standard conditions which is a result of
any of the processes listed under ‘process emissions’
97
98

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EUROPEAN COMMISSION

Brussels, 13 December 2023

GUIDANCE DOCUMENT ON CBAM IMPLEMENTATION FOR

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

Date Version notes

2.1 About this document 6

2.2 How to use this document 7

2.3 Where to find further information 7

3 QUICK GUIDE FOR IMPORTERS 10

4 THE CARBON BORDER ADJUSTMENT MECHANISM 15

4.1 Introduction to the CBAM 15

4.2 Definitions and scope of emissions covered in the CBAM 16

4.3 Transitional period 17

5 CBAM GOODS AND PRODUCTION ROUTES 26

5.1 Foreword to sector specific sections 26

5.2 Identifying CBAM goods 26

5.3 Cement sector 28

5.4 Chemicals sector – Hydrogen 34

5.5 Fertilizers sector 37

5.7 Aluminium sector 60

6.2 Reporting requirements 73

6.3 Reporting template 78

7 EXEMPTIONS FROM THE CBAM 87

ANNEX A LIST OF ABBREVIATIONS 88

ANNEX B LIST OF DEFINITIONS 90

The Carbon Border Adjustment Mechanism (CBAM) is an environmental policy

Under the CBAM, in its definitive (post-transitional) period EU authorised declarants

2.1 About this document

• Chapter 4 provides an introduction to the CBAM and an overview of the

• Chapter 7 explains the general exemptions from the CBAM.

Presentation of numbers in EU documents

Thousands, and powers of 103n thereafter, are separated by a space, e.g.:

• fifteen thousand is written as 15 000

• fifteen million is written as 15 000 000

A series of icons are used throughout to help guide the reader:

Icon Description of use

Points to information of particular importance for importers and

Simplified! Highlights simplified approaches of the general requirements of

Used where recommended improvements are presented

Used where other documents, templates or electronic tools are

Points to examples given for the topics discussed in the

Highlights sections that refer to the definitive period of the

2.3 Where to find further information

Implementing Regulation (EU) 2023/1773: Commission Implementing

• Article 2 and Annex II Section 1 – provide definitions for common terms

All EU legislation can be found on: eur-lex.europa.eu/homepage.html

• A separate guidance document is provided by the European Commission for

What happens after the transitional period.

4.1 Introduction to the CBAM

The Carbon Border Adjustment Mechanism (CBAM) is an environmental policy

The CBAM will be introduced in phases as follows:

• Transitional period (1 October 2023 to 31 December 2025):

4.2 Definitions and scope of emissions covered in the CBAM

Implementing Regulation references:

Annex II, Section 1 Definitions.

The following terms are frequently used in this guidance document:

4.3 Transitional period

A summary of key elements of the transitional period is presented in Table 4-1.

Table 4-1 Transitional period – key points