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The EU says, “As of 1 January 2026, CBAM is applicable under its definitive regime.” The Commission’s overview is at taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en.
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What “carbon cost” means for an imported construction material
In procurement, “carbon cost” can mean the quantity of greenhouse-gas emissions embodied in the material, the money associated with a carbon-pricing system, or both. Keep the two calculations separate:
- Embedded emissions: tonnes attributed to the imported goods under the legally defined product boundary. This is an emissions quantity, not a monetary charge.
- Financial exposure: certificates or other payments required by a particular regime after its rules, default values, mark-ups, deductions and reporting obligations are applied.
This guide uses the European Union CBAM as the worked regulatory example because the official sources provide current methods and dates. CBAM covers selected goods in cement, iron and steel, aluminium and other sectors; it does not automatically cover every product sold under those broad names. Coverage follows the regulation’s goods list and the product’s customs (CN) classification.
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For a legal interpretation, start with Regulation (EU) 2023/956 at eur-lex.europa.eu/legal-content/EN/TXT/?toc=OJ%3AL%3A2023%3A130%3ATOC&uri=uriserv%3AOJ.L_.2023.130.01.0052.01.ENG. The regulation and its implementing acts, rather than a generic product-carbon-footprint formula, control an actual declaration.
Step 1: Confirm the destination, year and CBAM coverage
Before requesting emissions figures, write down the jurisdiction and import year. A shipment entering the EU in 2026 is assessed under the definitive regime that began on 1 January 2026. A shipment entering another market may face a different scheme—or none—and cannot be priced using CBAM figures without checking that market’s rules.
- Identify the importer and destination customs territory. Confirm that the goods are entering the EU customs territory if you intend to use CBAM.
- Record the import year. Default-value tables, certificate rules and reporting deadlines are year-specific.
- Obtain the exact CN code. Product names such as “steel coil” or “cement” are not enough to establish coverage.
- Check the CBAM covered-goods list. Use the current regulation and Commission guidance, including amendments and corrections.
- Document any exclusions or special treatment. Keep the classification decision with the shipment file so a later estimate can be reproduced.
The Commission maintains legislation and guidance at taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en.
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Two products with the same commercial description can have different intensities because their processes, inputs and electricity sources differ. Ask the producer to identify the installation, country, reporting year and route, not just the product name.
Steel and iron goods
Steel calculations can depend on the route used at the installation and on inputs such as iron, steel or other precursors. A route-specific intensity supplied for one plant cannot be transferred to a different plant or product without checking the applicable method. The CBAM rules specify which direct, indirect and precursor emissions belong inside the product boundary.
Aluminium goods
Aluminium emissions vary with the production installation, process inputs and electricity information. Request the producer’s specific embedded emissions for the covered good and the supporting activity data required by the applicable CBAM method. Do not substitute a country-average footprint or a primary-aluminium figure for a product made by another route unless the rules expressly permit it.
Cement goods
For cement, the covered product and production information determine the boundary. Process emissions and relevant fuel, electricity and precursor information may be required. A generic “tonnes of cement” footprint can be unsuitable if the CN code or covered product differs from the one in the estimate.
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Step 3: Request the records needed for a defensible estimate
Send the producer a data request that identifies the exact installation and period. The following checklist covers the minimum information normally needed before applying the relevant method.
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| Information | What to request | Why it matters |
|---|---|---|
| Jurisdiction and import year | Destination customs territory and year of entry | Determines whether CBAM applies and which rules and default table are current |
| Customs classification | CN code and clear product description | Establishes whether the particular good is listed and which method applies |
| Shipment quantity | Quantity, unit and shipping documentation | Provides the multiplier for converting intensity into shipment tonnes |
| Installation identity | Producing plant and country or territory | Links the value to the actual source and geographic entry in the rules |
| Production route | Route and relevant process description | Routes can have different boundaries, precursors and default values |
| Specific embedded emissions | Producer’s value per unit for the covered good and reporting year | Allows an actual-value calculation when adequately determined |
| Activity and process data | Fuel, process, electricity and precursor information required by the method | Supports derivation and checks the declared boundary |
| Verification status | Whether the figures were verified and by whom under the applicable rules | Actual values in the EU explanation require verified third-country producer data |
| Default-value source | Official country, territory, product and route entry if actual data are unavailable | Makes a fallback estimate traceable to the correct table and year |
Ask for the records behind the number, not merely a rounded intensity in an email. Retain production output, emissions calculations, meter or fuel records and verification evidence for the period used. The exact data set depends on the product method in the implementing rules.
Step 4: Calculate embedded emissions with actual producer values
Use actual values only when they can be determined under the applicable CBAM methodology and supported by the required records. The conceptual calculation is:
Shipment embedded emissions (t CO2e) = imported quantity (product unit) × specific embedded emissions (t CO2e per product unit)
- Convert the invoice, customs and production quantities to the same product unit used by the intensity value.
- Confirm that the intensity covers the same CN-coded good, installation, route and reporting year as the shipment.
- Check which direct emissions, indirect emissions and precursors the method includes. Do not add arbitrary upstream or downstream life-cycle stages.
- Multiply quantity by intensity and preserve the calculation precision in the working paper.
- Attach the producer’s supporting records and verification status to the result.
- Repeat the calculation for each distinct product, installation or route rather than averaging unlike values.
For complex goods, apply the regulatory method to each included precursor and component. Adding a separate supplier footprint to the finished-product figure can double-count emissions when the precursor is already included.
Step 5: Use a default value when actual emissions cannot be adequately determined
The foundational regulation provides default values for cases in which actual emissions cannot be adequately determined. Select the current Commission value for the specific covered good, country or territory and production route where the table distinguishes routes. Record the table’s publication or correction date and the assumption that triggered the fallback.
Commission Implementing Regulation (EU) 2026/1740 corrected the 2026 default-value act. Its instruction is to use the “Other countries and territories” value when a country or territory is not explicitly listed, and also when a listed entry has no value for the relevant good. The correction is available at eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AL_202601740.
| Import or certificate year | Mark-up specified for default-value certificate calculation | Sectors named in the 2026 correction |
|---|---|---|
| 2026 | 10% | Cement, iron and steel, and aluminium |
| 2027 | 20% | Cement, iron and steel, and aluminium |
| 2028 and later | 30% | Cement, iron and steel, and aluminium |
These percentages are certificate-calculation rules stated in the act. They are not a 10%, 20% or 30% increase to every product’s physical carbon footprint. Keep the selected default intensity and the certificate mark-up as separate lines in your worksheet.
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Do not equate embedded tonnes with the amount payable. A financial estimate requires the current-year certificate-calculation rules, the applicable default-value table and any permitted adjustments or deductions. The number of certificates is derived under CBAM’s legal method; the value of those certificates and the surrender process are separate from the physical emissions calculation.
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The Commission’s 2026 explanation says importers may report using actual or default values. Where actual values are used, the producer in the third country must provide verified emissions data. It identifies 30 September 2027 as the first declaration deadline for embedded emissions from 2026 imports, with the corresponding certificate surrender. Read the notice at op.europa.eu/en/publication-detail/-/publication/79179e7b-6eab-11f1-ae88-01aa75ed71a1/.
For an internal budget, show at least three lines:
- Quantity multiplied by the applicable embedded-emissions intensity.
- Any default-value mark-up required for the certificate calculation.
- The resulting certificate quantity and the current certificate-price or adjustment rule used for the estimate.
Label the result as an estimate until the importer’s authorised declaration process confirms the final amount. Never apply the default mark-up to a supplier’s footprint as if it were a general life-cycle adjustment.
A practical worksheet for each shipment
Create one worksheet per product and installation. The following sequence keeps physical emissions and money auditable:
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- Enter the EU importer, installation, country or territory, CN code, product description and import year.
- Enter the shipment quantity and unit exactly as shown in customs records.
- Mark the calculation as actual or default.
- For actual values, enter the producer’s verified specific embedded emissions, reporting period, route and boundary description.
- For default values, enter the official product, geography and route entry, the publication or correction date and the reason actual values were unavailable.
- Calculate embedded tonnes with consistent units.
- Apply the current certificate-calculation provisions, including the year-specific mark-up where required.
- Record any adjustment, deduction or other rule that changes certificate surrender.
- Attach customs documents, producer records, verification evidence and the version of each official table used.
If a shipment combines products from different installations or routes, split the worksheet so each line uses the correct intensity. If the supplier changes plants during the reporting year, preserve the dates and quantities for each plant.
How to compare supplier offers without misleading yourself
When two suppliers provide emissions figures, compare like with like before choosing a lower number. Use this sequence:
| Comparison check | Question to ask | Reason |
|---|---|---|
| Functional unit | Are both values expressed per the same product unit? | Different units can make identical performance look different |
| Product and CN code | Do both values cover the same legally relevant good? | A commercial label may hide different covered products |
| Installation and route | Do the figures come from the actual plants and production routes? | Process and input differences affect intensity |
| Boundary | Do both include the same direct, indirect and precursor components? | Different boundaries are not a valid ranking |
| Reporting period | Are the years comparable with the import year and applicable rule? | Methods and plant performance can change over time |
| Verification | Are actual figures supported by the required verification? | Unverified marketing figures may not be usable for a declaration |
| Default source | If a default is used, is the same country, territory, route and year selected? | Official defaults differ by geography, product and route |
Only after these checks should a procurement team compare intensities or estimate the effect on certificate requirements. A lower number with a narrower boundary is not necessarily a lower CBAM value.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Common errors and how to correct them
Using a generic material footprint
Problem: A database average is applied to every steel, aluminium or cement purchase.
Correction: Verify the CN code, installation, route and method first. Use an official default only when actual values cannot be adequately determined and document the selected entry.
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Confusing tonnes with money
Problem: Embedded tonnes are presented as the final charge.
Correction: Calculate physical emissions separately, then apply the current certificate rules, mark-up and adjustments.
Applying the 2026 mark-up to the footprint
Problem: The 10% figure is added to the supplier’s emissions intensity.
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Correction: Keep the 10% 2026 mark-up in the certificate-calculation section. It is not a universal product-carbon-footprint multiplier.
Choosing the wrong fallback geography
Problem: A neighbouring country’s default is used because the exporter’s country is absent.
Correction: The 2026 correction directs users to “Other countries and territories” when the country is not listed or a listed entry has no value.
Mixing transitional and definitive-period rules
Problem: A pre-2026 transitional estimate is used for definitive-period imports.
Correction: Rebuild the worksheet under the rules for the actual import year. The first declaration deadline of 30 September 2027 covers 2026 imports; it does not place those imports outside the definitive regime.
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Adding life-cycle stages that CBAM does not require
Problem: Transport to the construction site, use phase or end-of-life emissions are added automatically.
Correction: Follow the CBAM product boundary and implementing rules. A CBAM estimate is not automatically a full life-cycle assessment.
Keeping the estimate current
Default values, corrections and reporting instructions can change. Before issuing a purchase decision or preparing a declaration, check the current Commission legislation and guidance, the relevant default-value table and the product’s implementing method. Commission Implementing Regulation (EU) 2026/1740 was published as a correction in July 2026, illustrating why an old spreadsheet can become unreliable.
Maintain versioned records for each estimate: the import year, CN code, quantity, installation, route, producer data, verification, default entry, mark-up, certificate rule and date accessed. If a supplier later supplies verified actual values, replace the default calculation and retain the original version so the change is explainable.
What this method can—and cannot—tell a construction team
This approach can produce a traceable estimate of embedded emissions and potential EU CBAM certificate exposure for covered imported goods. It supports tender comparisons, supplier data requests, budgeting and declaration preparation.
It cannot produce a universal carbon price for steel, aluminium or cement, determine coverage without a CN code, or replace the importer’s legal declaration. It also cannot calculate a complete life-cycle assessment unless you separately define and model stages outside the CBAM boundary. Where shipment quantity, origin, route or supplier data are missing, the honest result is an identified data gap or a clearly labelled official-default estimate—not a fabricated tonne or euro figure.
For the governing texts and updates, use the Commission’s CBAM overview, the foundational regulation, the implementing regulations and the legislation page linked above. Those sources should be checked again whenever the import year, product classification or default-value table changes.
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