Methodology
Embedded emissions: methodology
How embedded direct and indirect emissions are determined for CBAM goods, including system boundaries, default values, and verification.
Direct answer
Embedded emissions are the greenhouse gas emissions associated with producing a tonne of CBAM goods, calculated at installation level using the system boundaries set in the CBAM Implementing Regulation. They cover direct emissions from the production process; for some goods, indirect emissions from purchased electricity are included. Default values may be used only where actual installation data is not available and within the limits set by the Commission.
System boundary
The system boundary follows the production route for each CBAM good. It captures fuel and process emissions of the production process and, where relevant, of upstream precursors. The Commission's sectoral communication templates set out the boundary for cement, steel, aluminium, fertilisers, and hydrogen.
Direct and indirect emissions
Direct emissions arise from the installation itself. Indirect emissions cover emissions associated with the production of electricity consumed during manufacturing. For some CBAM goods indirect emissions are part of the embedded emissions; for others they are reported but not priced. Always read the specific rule in the Implementing Regulation for the good concerned.
Default values
Default values published by the Commission are intended as a fallback where actual installation data cannot reasonably be obtained. From 2026 onwards the use of defaults is restricted in line with the rules of the definitive regime and the Commission guidance.
Verification
Verification of embedded emissions follows the principles of EU ETS verification and is carried out by an accredited verifier. The verifier confirms that the data, methods, system boundaries, and supporting documentation comply with the Implementing Regulation.