Buyer
When can you send the 2026 figures?
Embedded Emissions Management System
Don't pay the default value.
From your meter, ERP and lab data, product-level* embedded emissions calculated under the EU CBAM method rules — a preparation file for the declaration and for independent verification.
sample data · fictional screen, not a working connection
CN 7214 20 00 · 2026 · tCO₂/t
Ø12 mm ribbed rebar0.68
Ø16 mm ribbed rebar0.67
Billet 130×130 mm0.54
Wire rod 5.5 mm0.71
Profile L500.74
Angle bar0.73
Welded mesh0.80
CN 7214 20 00Ribbed rebar · EAF
0.68 tCO₂ / t
Embedded emissions · Annex IV · Q1 2026 · fictional inputs, both per tonne of product
Direct emissionsMeter + fuel analysis0.41
Precursor (billet)Supplier declaration0.27
ElectricityOut of scope, definitive regime—
Default value (2026, mark-up included)2.541 tCO₂e/t
− Fictional SEE input: 0.68 tCO₂e/t
= Difference per tonne × Q2 2026 import price (€75.28)€140.10/t
Q2 2026 imports · Commission, 06.07.2026 · SEFA (IR (EU) 2025/2620) not included — a worked example, not an amount payable
2028 mark-up 30% → €174.88/t · If the Q2 2026 price (€75.28) stayed the same in 2028 — a scenario, not a forecast
Declaration status2026
Data collected
Calculation complete
Evidence chain
Verifier
Delivered to buyer
Buyer
Ravenna, Italy
CBAM definitive regime
Definitive regime starts:1 January 2026Certificate sales open:1 February 2027First declaration and surrender:30 September 2027Certificate price:Q1 €75.36 · Q2 €75.28 · Q3 €82.32 · Q4: no amount (2026 import quarter; snapshot 05.10.2026)Sectors in legal scope:6De minimis threshold:50 t net mass per importer per calendar year (not electricity or hydrogen)Steel scope:Direct emissionsVerification:Accredited verifier on the actual-values route
What does declaring on the default value cost you?
No verified sector average exists for this product. Enter your own measured value — an invented average would be the weakest link in this calculation.
- Raw default value
- 1.41 tCO₂e/t
- With the default-value increase (mark-up), computed (2026 10%)
- 1.551 tCO₂e/t
Pick a product and enter your actual emissions value.
With no data of your own, you are priced on the default value. And that value grows each year until 2028.
Cement
Grey cement clinkerCN 2523 10 00Raw default value, other-countries fallback1.41 tCO₂e/t
Applicable default value, 20261.551 tCO₂e/t
Gap to an actual valuenot calculated
Türkiye is listed in Annex I but its clinker rows are blank, so the "other countries" fallback applies: other clinker including grey clinker, TARIC 2523 10 00 90, 1.410 × (1 + 10%, 2026). It does not extend to white clinker. Clinker and cement (CN 2523 29 00) are separate CBAM goods.
This page has no full SEE for cement that could be compared with the default value. The demo's 0.88 tCO₂/t — fictional direct-emissions example (fuel 0.33 + process 0.55). No indirect share; not a full SEE, no difference to the default is computed. The default value also includes indirect emissions — the Annex I row reads: direct 1.370 · indirect 0.050 · total 1.410 tCO₂e/t (IR (EU) 2026/1740, other-countries table, p.1839). Default: IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740.
Steel
Hot-rolled flat productCN 7208Raw default value, Türkiye2.428 tCO₂e/t
Applied value, 2026 (10% mark-up)2.671 tCO₂e/t
Applied value, 2028 (30% mark-up)3.156 tCO₂e/t
Default value, 2026 to 2028+18%
Unlike cement, Türkiye has its own listed values for steel in Annex I; this row is not a fallback. Marked-up figures are not published there — IR (EU) 2026/1740 removed those columns — and are derived from the total-emissions column: 2.428 × 1.10 = 2.6708 and 2.428 × 1.30 = 3.1564, rounded to three decimals. What grows is the marked-up intensity of the default value (3.1564 / 2.6708 − 1 = 18.18%), not the certificate price or the real cost. The simulator's difference is a worked example with the SEFA effect left out.
IR (EU) 2025/2621 Annex I, as replaced by IR (EU) 2026/1740.
If you sell steel, cement or aluminium into the EU, the carbon in your product is now a line on your buyer's invoice.
See the CBAM timelineMeters
SCADA
MES
LIMS
ERP
Weighing
Shifts
Recipes
Energy
Fuel
Power
Precursors
One place for the whole declaration.
From raw plant data to a verification-preparation file.
Data collection from meters, SCADA, ERP and the lab
Data sources
Natural gas meterModbusexample scenario
Electricity meterModbusexample scenario
Production (ERP)RESTDaily
Fuel analysisLIMSMonthly
WeighingCSVPer shift
PrecursorSupplierDeclaration
Product-level maths Annex IV method, per CN code
Annex IV · calculation
Fuel combustion0.286
Process emissions0.074
Heat (imported)0.050
Precursor0.270
Total0.68
Verification-preparation pack with the evidence chain for an independent verifier to assess
Verification-preparation file
PDFMeter calibration certificate
PDFFuel analysis report 2026-03
CSVProduction records Q1
XMLPrecursor declaration
XLSXCalculation ledger
PNGSystem boundary diagram
Handover to the buyer preparation data for their declaration (target)
Ravenna, ItalyXML · CBAM
Hamburg, GermanyXLSX
Fos-sur-Mer, FrancePDF + XML
Cost by line which furnace drives your per-tonne load
Load by line · tCO₂/t
EAF 10.58
EAF 20.64
Rolling 10.71
Rolling 20.92
Reheating furnace0.66
Example user threshold 0.78 · not an official or measured sector benchmark
Five groups of sources, none of them talking
This is what one product's emissions declaration looks like today.
One preparation file
EEMS aims to bring these five groups of sources into one calculation; the output is a preparation file for the declaration and for independent verification.
sample data · fictional screen, not a working connection
Lab
analysis-2026-03.pdf
Meter
Natural gas consumption
CBAM Regulation
Annex IV — calculation
Inbox
3,209 unread
Shared drive
[draft] declaration v7
ERP
Output: 12,400 t billet
Excel
calc_final_FINAL.xlsx
Consultant
Revision notes
Product · Reinforcing barFictional example
Direct emissionsMeter + fuel analysis0.41
Precursor (billet)Supplier declaration0.27
ElectricityOut of scope, definitive regime—
Total embedded emissions — fictional inputs, both per tonne of product0.68 tCO₂/t
Default value (2026, mark-up included)2.541 tCO₂e/t
− Fictional SEE input: 0.68 tCO₂e/t
= Difference per tonne × Q2 2026 import price (€75.28)€140.10/t
Q2 2026 imports · Commission, 06.07.2026 · SEFA (IR (EU) 2025/2620) not included — a worked example, not an amount payable
2028 mark-up 30% → 3.003 tCO₂e/t, difference €174.88/t · If the Q2 2026 price (€75.28) stayed the same in 2028 — a scenario, not a forecast · CN 7214 20 00
We don't interpret the regulation. The method is written into the product.
See the calculation methodSystem boundary
Fuel combustion
Process emissions
Heat and steam
+ Embedded emissions of precursors
Electricity — out of scope for iron and steel in the definitive regime
The methodology is built in. System boundaries, precursors and measurement rules, per Annex IV.
Direct embedded emissions are determined as the sum of the direct emissions within the system boundaries of the production process and the direct embedded emissions of the relevant precursors.
CBAM Regulation (EU) 2023/956
Annex IV — Calculation of embedded emissions
Verification preparationchecklist
- Measurement equipment calibration
- Data flows and controls
- System boundary accuracy
- Precursor evidence
- Calculation is reproducible
A preparation file for independent verification. The evidence chain is gathered in the file; the assessment and the decision belong to the independent verifier.
Where the embedded emissions are determined on the basis of actual emissions, the authorised CBAM declarant shall ensure that the total embedded emissions declared are verified by a verifier accredited pursuant to Article 18.
CBAM Regulation (EU) 2023/956, as amended by (EU) 2025/2083
Article 8(1) — Reg. (EU) 2025/2083 Art. 1(7), p.10 · accreditation: Delegated Regulation (EU) 2025/2551 (verifier definition Art. 1(1), p.4)
Producer
Embedded emissions declaration
CN 7214 20 00 · 0.68 tCO₂/t (fictional)
EU importer
Authorised CBAM declarant
Aims to produce preparation data your buyer can use in their declaration. The declaration is made by the EU importer, as the authorised CBAM declarant.
The authorised CBAM declarant declares, for each calendar year, the embedded emissions of the goods imported and surrenders the corresponding certificates.
CBAM Regulation (EU) 2023/956
Articles 6–8 — Declaration, calculation, verification
Let us produce a sample declaration from your own data.
One product, one production line. The timeline is planned at the first assessment, according to the data in scope; you end up holding a preparation file for the declaration and for independent verification.
Many plants.One preparation file.
The aim: one calculation record for group structure, separate lines and EU buyer templates.
The Commission sets default values on the conservative side, for producers with no actual data. With real figures, you close that gap yourself.
Your buyer needs your embedded-emissions data for their declaration. The Annex IV communication template covers more fields than the emissions intensity (IR (EU) 2025/2547 Annex IV, p.78–85); which fields are shared is agreed with the buyer.
Where embedded emissions are determined on the basis of actual emissions, the declared total is verified by an accredited verifier (amended Art. 8(1), Reg. (EU) 2025/2083, p.10). Verifier accreditation: Delegated Regulation (EU) 2025/2551 (verifier definition Art. 1(1), p.4).
For iron and steel, aluminium and hydrogen, the definitive regime covers direct emissions only. Cement and fertilisers also include indirect emissions.
A carbon price effectively paid can be deducted if documented — but only where your embedded emissions rest on actual data; a default-value declaration closes that route. Any rebate or compensation received is taken into account (amended Art. 9(1), Reg. (EU) 2025/2083, p.10). Free allocation is not a payment. Türkiye's ETS regulation was published on 27 August 2026, leaving the pilot's scope and free-allocation rate to the Carbon Market Board. The deduction needs the installation's documented, effective payment; free allocation is not enough.
Where measurement is absent, a calculation-based method applies; both require records and evidence.
The declaration for 2026 imports is filed on 30 September 2027. Your buyer will want the figures long before that, so in practice your clock runs earlier.
An importer is exempt where the total net mass of goods it imports in a calendar year does not exceed 50 tonnes; cross the threshold during the year and the obligation applies to all goods imported that year. The measure is net mass, not the number of containers. The exemption does not apply to imports of electricity or hydrogen (Art. 2a(1), (2), (4) inserted by Reg. (EU) 2025/2083, p.7; Annex VII, p.24).
From your supplier. If you buy a relevant precursor — billet, clinker, or unwrought aluminium for aluminium products — its product-level data is needed too; building that chain is your job. Relevant precursors follow the production route (IR (EU) 2025/2547 Annex I §3; aluminium: §3.17–3.18, p.25–26).
No. The EU importer buys certificates. The price is the average of EU ETS auction closing prices: weekly is the rule, but a one-year exception applies for 2026 — that year's imports are priced on a quarterly average.
Don't pay the default value.
Write to us about CBAM declaration preparation.