Key facts: CBAM entered full enforcement in January 2026. Cement, fertiliser and hydrogen exporters to the EU must provide verified embedded emissions data. The first annual CBAM declaration covers calendar year 2026 and is due 31 May 2027. Default values are still permitted but are set high enough to make actual measurement financially compelling.
Which Cement, Fertiliser & Hydrogen Products Are Covered?
CBAM Regulation (EU) 2023/956 and its Implementing Regulation (EU) 2023/1787 define covered goods by Combined Nomenclature (CN) code. For your shipments to trigger CBAM obligations, the CN code on your export declaration must appear in Annex I.
| Sector | Key CN Codes | Typical Product |
|---|---|---|
| Cement | 2523 10, 2523 21, 2523 29, 2523 30, 2523 90 | Clinker, Portland cement, aluminous cement |
| Fertilisers | 3102 10, 3102 30, 3102 40, 3102 50, 3102 80, 3105 20, 3105 51, 3105 59 | Urea, ammonium nitrate, NPK blends |
| Hydrogen | 2804 10 00 | Grey, blue, green hydrogen |
| Precursors | 2814 (ammonia), 2808 (nitric acid) | Used in fertiliser manufacturing chains |
Embedded Emissions Calculation: Cement
Cement is one of the most carbon-intensive CBAM sectors because calcination of limestone releases CO₂ regardless of fuel type — this process emission cannot be eliminated by switching to renewables.
Direct Emissions (Scope 1) for Cement
- Calcination: CaCO₃ → CaO + CO₂ — typically 0.50–0.55 tCO₂ per tonne of clinker produced
- Fuel combustion: kiln fuel (coal, petcoke, alternative fuels) — typically 0.25–0.35 tCO₂/t clinker
- Other on-site combustion: raw meal drying, grinding, cooling
Indirect Emissions (Scope 2) for Cement
Grid electricity consumed in grinding, conveying and auxiliary processes. Must use the country-specific grid emission factor published by the CBAM authority or your national grid operator. Self-generated renewable electricity may be excluded with documentation.
📊 Typical Embedded Emissions for Cement
Portland cement (OPC): 0.75–0.90 tCO₂e per tonne. Blended cements (with fly ash or GGBS replacing clinker) can be 0.50–0.70 tCO₂e/t. The EU CBAM default value for cement is approximately 0.94 tCO₂e/t — most well-operated plants will benefit from using actual figures.
Embedded Emissions Calculation: Fertilisers
Fertiliser emissions are complex because they involve both the direct manufacturing emissions and the emissions embedded in precursor gases (ammonia, nitric acid) that feed into the final product.
Urea (CN 3102 10)
Urea synthesis requires ammonia (from natural gas steam methane reforming) and CO₂. The embedded emissions are dominated by the Haber-Bosch process: approximately 1.6–2.0 tCO₂e per tonne of urea. Plants with carbon capture from the ammonia loop will have lower figures.
Ammonium Nitrate (CN 3102 30)
Ammonium nitrate (AN) embedded emissions include both the ammonia production and the nitric acid synthesis. Nitrous oxide (N₂O) from nitric acid production is a significant contributor — 1 kg N₂O has a GWP of 273. EU default for AN: approximately 2.3 tCO₂e/t.
NPK Blends
Mixed fertilisers under CN 3105 require a weighted allocation of embedded emissions from each nitrogen, phosphorus and potassium component. The CBAM implementing regulation provides specific calculation rules for blended products.
Embedded Emissions Calculation: Hydrogen
Hydrogen is unique among CBAM goods because embedded emissions vary by a factor of 100+ depending on the production route. The EU will not accept a blanket declaration — the production pathway must be documented.
| Production Route | Embedded Emissions (kgCO₂e/kg H₂) | CBAM Cost at €65/tCO₂ |
|---|---|---|
| Grey (SMR, no CCS) | 9–12 | €0.59–€0.78/kg H₂ |
| Blue (SMR + CCS 90%) | 1.0–2.5 | €0.07–€0.16/kg H₂ |
| Green (electrolysis, renewables) | 0.5–1.5 | €0.03–€0.10/kg H₂ |
| Default (if no data provided) | ~15.0 | €0.98/kg H₂ |
Default vs Actual Values: The Financial Case
Default CBAM values are published by the European Commission and are deliberately set at the 75th percentile of EU ETS installation benchmarks — meaning most non-EU exporters will pay more using defaults than actual figures. The table below illustrates the difference for a mid-size cement exporter:
💰 Cost Example: 50,000 t Cement, Carbon Price €65/tCO₂e
- Default value (0.94 tCO₂e/t): 50,000 × 0.94 × €65 = €3,055,000
- Actual value (0.78 tCO₂e/t, well-operated kiln): 50,000 × 0.78 × €65 = €2,535,000
- Saving from actual measurement: €520,000/year
Key Dates for Cement, Fertiliser & Hydrogen Exporters
| Date | Obligation |
|---|---|
| January 2026 | CBAM definitive phase begins — certificates must be purchased |
| Q1–Q4 2026 | Track embedded emissions for all CBAM-covered shipments throughout the year |
| 31 May 2027 | First annual CBAM declaration filed by EU authorised declarant covering full calendar year 2026 |
| 31 May 2027 | CBAM certificates surrendered equal to total verified embedded emissions |
| Annually thereafter | Annual declaration due 31 May each year |
What Non-EU Exporters Must Provide to Their EU Importer
As a non-EU cement, fertiliser or hydrogen producer, your CBAM obligations run via the EU-based importer (authorised declarant). However, you are the only party who can provide the actual emissions data. You must supply:
- Embedded emissions per tonne per CN code, calculated per the CBAM implementing regulation methodology
- Supporting evidence: energy consumption logs, production data, emission factor sources
- For hydrogen: production route documentation and electrolyser efficiency data
- Third-party verification report (required from 2026 for actual values)
- Carbon pricing paid in country of origin (may be deducted from CBAM liability)
Frequently Asked Questions
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