On this page
- Who needs a CBAM embedded emissions calculation
- Installation boundaries and production processes
- Direct and indirect emissions
- Precursors and complex goods
- Monitoring methodology
- How we run an embedded emissions project
- Errors we often find in plant data
- What you receive
- Verification readiness
- What determines cost and timeline
We calculate CBAM embedded emissions for installations outside the EU, mainly in Turkey, that produce cement, iron and steel, aluminium, fertilisers or hydrogen for EU customers. The work follows the definitive-period method in Implementing Regulation (EU) 2025/2547 and ends with a product-level data set your importers can use and an accredited verifier can check.
Who needs a CBAM embedded emissions calculation
Any plant whose goods are imported into the EU under a CN code in Annex I of Regulation (EU) 2023/956 will be asked for its specific embedded emissions. The legal obligation sits with the EU importer, but only the producer can supply actual data. Without it, the importer must use the Commission's default values plus a mark-up of 10% in 2026, rising to 30% from 2028 for most goods, and the cost of that usually shows up in price negotiations with the supplier.
Typical clients are Turkish steel mills and pipe makers, cement and clinker plants, aluminium extruders and casthouses, and nitrogen fertiliser producers. Traders that buy from several plants also use the service to collect consistent data.
Installation boundaries and production processes
CBAM calculations start with the installation, meaning the stationary technical unit where the production process takes place, and with a list of production processes inside it. Each process is defined by the goods it makes, and every emission source, fuel and electricity flow must be allocated to one of them. Where an installation also makes non-CBAM products, those flows are separated out.
Getting the boundary right matters more than any later calculation step. Common problems we see in Turkish plants are shared boilers serving several lines, gas meters that cover more than one process, and on-site power plants whose electricity and heat need to be split between production lines and exports to the grid.
| Sector | Typical production processes | Relevant precursors |
|---|---|---|
| Cement | Clinker production, cement grinding | Clinker |
| Iron and steel | Sintering, pig iron, DRI, crude steel (BOF or EAF), iron or steel products | Sinter, pig iron, DRI, crude steel, ferro-alloys, hydrogen |
| Aluminium | Unwrought aluminium (primary or secondary), aluminium products | Unwrought aluminium |
| Fertilisers | Ammonia, nitric acid, urea, mixed fertilisers | Ammonia, nitric acid, urea, hydrogen |
| Hydrogen | Hydrogen production | None |
Direct and indirect emissions
Direct emissions come from fuel combustion, process reactions such as limestone calcination or anode consumption, and measurable heat imported into the process. Nitrous oxide from nitric acid and perfluorocarbons from primary aluminium also count. Indirect emissions are those from the electricity a process consumes.
In the definitive period, indirect emissions are part of the CBAM obligation only for cement and fertilisers. For iron and steel, aluminium and hydrogen the obligation is based on direct emissions. We still calculate electricity consumption for all sectors, because importers and EU customers often ask for it and the scope can change.
The emission factor for electricity is normally the default grid factor published for the country of production. An actual factor can be used only in defined cases, such as a direct technical connection to a generating plant or a power purchase agreement that meets the conditions in the implementing rules.
Precursors and complex goods
A complex good is one that contains precursors with their own embedded emissions. Cement contains clinker, a steel tube contains crude steel, and a nitrogen fertiliser contains ammonia. The embedded emissions of the final product are the emissions attributed to its own process plus the embedded emissions of the precursor quantities consumed.
Where the precursor is made on site, we calculate it as a separate process. Where it is bought in, the supplier's specific embedded emissions are needed. For a Turkish pipe maker buying hot-rolled coil from another mill, that means a second data request, and we often handle that contact directly in Turkish.
Monitoring methodology
Each source stream is monitored with either a calculation-based approach (activity data times emission factor, with oxidation or conversion factors) or a measurement-based approach using continuous emission monitoring systems. Mass balance is common in steel and aluminium, where carbon enters and leaves in several materials. The method for each stream, the meters and laboratory analyses behind it, and the control activities are written up in the installation's monitoring documentation.
Plants already covered by the Turkish MRV regulation have a monitoring plan approved by the Ministry of Environment, Urbanisation and Climate Change. We build on it, add process-level attribution and product data, and record where CBAM rules differ, for example in how heat and waste gases are treated between processes.
How we run an embedded emissions project
- Scope and CN code mapping (1 week). Products sold to the EU, CN codes, sectors and the reporting period, normally the calendar year.
- Site visit and boundary definition (1 to 2 weeks). Walk-through with production, energy and laboratory staff, meter mapping, process flow diagram.
- Data collection (2 to 4 weeks). Fuel and material quantities, analyses, electricity readings, production volumes, precursor purchases.
- Calculation and attribution (2 to 3 weeks). Emissions per process, specific embedded emissions per product, cross-checks against EU benchmarks and default values.
- Documentation (1 to 2 weeks). Monitoring methodology document, calculation workbook, evidence index.
- Importer communication (1 week). One data set per customer, with an English method summary.
- Verification support. Pre-verification check, site visit support, corrective actions.
Errors we often find in plant data
Some issues come up in nearly every first CBAM calculation. Electricity is metered only at the site connection point, so consumption has to be split between processes on engineering estimates that a verifier will question. Natural gas used in offices, canteens or non-CBAM lines is counted as process fuel. Laboratory analyses of fuel or raw meal are done in-house without a documented method or are too infrequent to support the reported values.
In steel and aluminium plants, scrap and alloying materials are often not recorded with enough detail to identify precursors. In fertiliser plants, the N2O measurement system may exist but lack the quality assurance records the rules expect. We list these gaps early, propose practical fixes (an extra sub-meter, a sampling plan, a written procedure) and agree with you which can be closed before the reporting year ends.
What you receive
You receive specific direct and indirect embedded emissions per product group, in tonnes of CO2e per tonne of product, with the underlying production volumes. Where the importer needs it, we add the information required for the free allocation adjustment and the production route used.
The importer data is delivered in the Commission's communication template for installations or in an agreed equivalent format. Behind it sits a calculation workbook that traces each figure back to an invoice, meter reading or laboratory report, which is what the verifier will sample.
Verification readiness
From the 2026 reporting year, an importer can use actual embedded emissions in its annual CBAM declaration only if they have been verified by a verifier accredited under Delegated Regulation (EU) 2025/2551, following the principles in Implementing Regulation (EU) 2025/2546. The first verification of an installation requires a physical site visit. Accreditation of verifiers only started in the second half of 2026, so capacity is limited and early booking helps.
Ekol Çevre is a consultant, not a verifier. We prepare the monitoring documentation and evidence, run an internal pre-verification review, coordinate with the verifier you appoint and support your staff during the site visit. Keeping the consultancy and verification roles separate is a requirement the verifier will check.
What determines cost and timeline
The main drivers are the number of production processes, whether precursors are made on site or bought, the quality of metering (especially sub-meters for electricity and gas), the availability of laboratory analyses, and how many EU customers need separate data sets. A cement plant with a valid MRV plan is usually a short project. An integrated steel works with sinter, blast furnace and rolling, or a fertiliser complex with ammonia, nitric acid and several finished products, takes longer.
The method is explained step by step, with an illustrative cement example, in our guide how to calculate CBAM embedded emissions. For the wider regulatory picture, see our CBAM consulting page. If your customers also ask for product footprints or EPDs, much of the same data feeds a product carbon footprint under ISO 14067.