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Lakshmikumaran and Sridharan attorneysNavigating CBAM

Sectors

Cement

Clinker, cement and downstream lines covered by CBAM, with the calcination/combustion split, default values and CN-code reference.

By Lakshmikumaran and Sridharan attorneysReviewed by LKS CBAM editorial team
Last reviewed: June 2026
On this page
  1. Direct answer
  2. What is covered
  3. Calcination vs combustion
  4. Precursors and the goods rule
  5. Default values for cement
  6. FAQ
  7. What to read next

Direct answer

The cement sector covers cement clinkers, Portland and aluminous cements, and related hydraulic cements listed by CN code in Annex I to Regulation 2023/956. Embedded emissions are dominated by process emissions from calcination of limestone, plus combustion emissions from the kiln fuel mix. Default values apply during the transition where verified actual emissions from the installation are not available.

What is covered

Six CN codes from Chapters 25 and 38 are in scope: cement clinkers (CN 2523 10), Portland cement (CN 2523 21, 2523 29), aluminous cement (CN 2523 30), other hydraulic cements (CN 2523 90) and kaolinic clays (CN 2507 20) used as supplementary cementitious material. The list is the legal reference; the covered goods checker maps a code back to its scope status.

6 CN codes in 4 sub-groups (Annex I, DG TAXUD)
Aluminous cement1
2523Aluminous cement1
2523 30Aluminous cement1
Calcined clay1
2507Other kaolinic clays1
2507 00Other kaolinic clays1
Cement3
2523Other Portland cement3
2523 21White Portland cement, whether or not artificially coloured1
  • 2523 21 00White Portland cement, whether or not artificially coloured
2523 29Other Portland cement1
2523 90Other hydraulic cements1
Cement clinkers1
2523Cement clinkers1
2523 10Cement clinkers1

Cement: process schematic

Sources

Calcination is the dominant emissions source; combustion adds kiln-fuel CO2. Both sit inside the installation boundary.

Implementing Regulation (EU) 2023/1773, Annex IV; sectoral communication template (cement)

Calcination vs combustion

Roughly two thirds of CO2 from clinker production come from process emissions: calcination of calcium carbonate (CaCO3 -> CaO + CO2). The remainder is combustion of the kiln fuel mix (coal, petcoke, alternative fuels). Both are reported on the system boundary set in the embedded-emissions methodology. The clinker-to-cement ratio drives the per-tonne intensity of finished cements, which is why CEM II/III blends with slag, fly ash or limestone filler have materially lower embedded emissions than CEM I.

Precursors and the goods rule

Cement is a finished good for CBAM purposes; clinker is a precursor of cement. When clinker is imported on its own, it is reported directly. When cement is imported, the embedded emissions of the clinker precursor are aggregated into the cement's embedded emissions using the installation's attribution methodology. Kaolinic clays calcined for use as supplementary cementitious material are in scope as a separate line.

Default values for cement

The EU Commission publishes default values per CN sub-good, including separate direct and indirect components and a tapering schedule for the transition years (2026, 2027, 2028 onward). The values below are filtered to the cement sector from the official spreadsheet; the full dataset is on the default values explorer.

Loading default values dataset...

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Source: Navigating CBAM by Lakshmikumaran and Sridharan Attorneys. Canonical: https://cbam.lkslaw.com/sectors/cement (ref 1w5rjzl). Reuse permitted under the site terms with attribution and a link back.

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