Articles

How do you calculate CBAM embedded emissions for cement?

For cement CBAM counts electricity too, and the clinker ratio does most of the work. Leaving out the indirect emissions under-declares almost a tenth.

Julian R. Sterling · from The CBAM Compliance Handbook

CBAM specific embedded emissions of cement are the grinding process's direct and indirect emissions plus the clinker consumed times the clinker's own specific embedded emissions, all divided by the tonnes of cement produced. On an illustrative integrated plant with clinker at 0.906 tonnes of CO2e a tonne and a clinker ratio of 0.76, the answer is 0.7226 tonnes of CO2e per tonne of cement. Unlike steel, the electricity counts: leaving it out under-declares by 9.8 per cent.

Worked in full in The CBAM Compliance Handbook by Julian R. Sterling, with every figure reproduced in a free workbook.See the book on Amazon →

The formula

Under Annex IV of Regulation (EU) 2023/956, the CBAM Regulation, cement is a complex good whose relevant precursor is cement clinker, itself a CBAM good. Each production process gets its own specific embedded emissions, and the precursor's figure is carried into the product's. Cement and fertilisers are the categories for which indirect emissions, those of the electricity consumed, are counted alongside direct emissions; iron and steel, aluminium and hydrogen count direct emissions only in the definitive period, as worked for an aluminium product in CBAM embedded emissions for aluminium products.

EF is the electricity emission factor. By default it is the factor of the grid in the country of origin; an actual factor is allowed only under the conditions Annex IV sets out, such as a direct technical link to a generator or a qualifying power purchase agreement.

The assumptions

A fictional integrated cement works outside the EU makes its own clinker in a kiln and grinds it with gypsum and limestone. Every figure is illustrative, chosen to be a plausible order of magnitude, not a published value.

Plant data for the reporting period

Input	Value
Clinker produced, tonnes	800,000
Direct emissions of the clinker process (calcination and kiln fuel), tCO2e	680,000
Electricity consumed by the clinker process, MWh	64,000
Cement produced, tonnes	1,000,000
Clinker consumed in grinding, tonnes	760,000
Direct emissions of grinding (dryers), tCO2e	6,000
Electricity consumed by grinding, MWh	40,000
Grid emission factor, tCO2e per MWh	0.70
Cement imported into the EU in the year, tonnes	50,000

The calculation, step by step

Step 1, the clinker. The kiln's electricity is 64,000 × 0.70 = 44,800 tonnes. Add the 680,000 of direct emissions and divide by the 800,000 tonnes of clinker: 0.906 tonnes per tonne, of which 0.850 is direct and 0.056 indirect.

Step 2, the grinding process. The mills' electricity is 40,000 × 0.70 = 28,000 tonnes, plus 6,000 direct from the dryers.

Step 3, the precursor carried in. Only the clinker consumed counts, 760,000 tonnes, a clinker ratio of 0.76. The other 40,000 tonnes were sold or stocked and carry their own embedded emissions wherever they go.

Where the 0.7226 comes from, per tonne of cement

Component	tCO2e
Grinding, direct	0.006
Grinding, indirect	0.028
Clinker precursor, direct and indirect	0.6886
Specific embedded emissions	0.7226

The result

The clinker carries 95.3 per cent of the cement's embedded emissions. The importer of 50,000 tonnes declares 36,128 tonnes of CO2e. That volume is far above the 50-tonne annual de minimis threshold introduced by the 2025 simplification of CBAM, whose arithmetic is worked in is it worth staying under the CBAM 50 tonne threshold. Split by type, 0.6520 per tonne is direct and 0.0706 indirect. At an illustrative 80 euros a certificate, once free allocation has been phased out, the full exposure is 2,890,240 euros, 57.80 per tonne of cement; the certificates surrendered in the early years are reduced by the free-allocation adjustment and by any carbon price effectively paid in the country of origin. How the factor phases in is worked, for steel, in how much CBAM will cost per tonne of steel from 2026 to 2034.

What if the plant changes?

Cement SEE and declared emissions on 50,000 tonnes

Variant	Clinker SEE	Cement SEE	Declared, tCO2e
Clinker ratio 0.65 (more limestone or slag)	0.906	0.6229	31,145
Base case, ratio 0.76, grid 0.70	0.906	0.7226	36,128
Clinker ratio 0.90	0.906	0.8494	42,470
Grid factor 0.20 (low-carbon grid)	0.866	0.6722	33,608
Grid factor 0.90 (coal-heavy grid)	0.922	0.7427	37,136

The clinker ratio dominates. Each 0.01 of ratio moves the cement figure by 0.0091, 453 tonnes on this import. The grid matters less: the plant uses 0.1008 MWh per tonne of cement through the clinker and the mills together, so each 0.10 of grid factor is worth 0.0101, about 504 tonnes. For a buyer comparing two cement suppliers, the blend is the first question and the power source the second.

The common mistakes

• Counting direct emissions only, as for steel. 0.6520 instead of 0.7226 under-declares 3,528 tonnes, 9.8 per cent. Under-declaration is the direction penalties are written for.
• Dividing the whole plant's emissions by cement output. Kiln plus mills over 1,000,000 tonnes gives 0.7588, and loads onto the cement the clinker that was sold: 1,812 tonnes over-declared on the import.
• Leaving the indirect emissions out of the clinker. The precursor's own SEE must include its electricity too; using 0.850 instead of 0.906 drops 0.0426 per tonne of cement.
• Using a contract factor without meeting the conditions. A supplier's green tariff does not replace the grid default unless Annex IV's conditions are met and documented.

Takeaway

• Cement SEE = (grinding direct + grinding indirect + clinker consumed × clinker SEE) / cement produced.
• For cement, both the clinker's and the grinding's electricity count.
• The clinker ratio is the lever: ask suppliers for it before you ask for anything else.
• Use clinker consumed, not produced, and keep sold clinker out of the cement.

The quarterly cash profile, the certificate buffer and a blank model for your own imports are in the free workbook for this book; the same method for a steel product is worked in how to calculate CBAM embedded emissions for a steel product.

Questions readers ask

Are indirect emissions included in CBAM for cement?

Yes. Cement and fertilisers count the emissions of the electricity consumed in production, unlike iron and steel, aluminium and hydrogen, which count direct emissions only. In the worked plant the indirect part is 0.0706 of the 0.7226 tonnes per tonne of cement, 9.8 per cent, or 3,528 tonnes on a 50,000 tonne import.

How does the clinker ratio affect CBAM embedded emissions?

Almost one for one, because clinker is the precursor that carries the kiln's process and fuel emissions. In the worked plant each 0.01 of clinker ratio adds 0.0091 tonnes per tonne of cement, 453 tonnes on a 50,000 tonne import. Moving from a ratio of 0.76 to 0.65 cuts the SEE from 0.7226 to 0.6229.

What electricity emission factor is used for CBAM indirect emissions?

By default, the emission factor of the grid in the country of origin. An actual factor can be used only under the conditions set out in Annex IV of the regulation, such as a direct technical link to a generator or a qualifying power purchase agreement. In the worked plant each 0.10 of grid factor moves the cement SEE by 0.0101, about 504 tonnes on the import.

Also on this site

• How do you calculate CBAM embedded emissions for a steel product?Process emissions plus precursor consumed times its SEE, over output. 2,400 plus 21,500 t of wire rod at 1.90, over 20,000 t, gives 2.1625 tCO2e a tonne.
• How do you calculate CBAM embedded emissions for aluminium?Direct emissions only: extrusion process plus billet consumed times its SEE, over output. An illustrative profile gives 2.1925 tCO2e a tonne, coal or hydro.
• How much will CBAM cost per tonne of steel from 2026 to 2034?At 2.0 tonnes of CO2 a tonne and an 80 euro certificate, CBAM costs 4.00 euros a tonne of steel in 2026, 77.60 in 2030 and 160.00 in 2034.
• Is it worth staying under the CBAM 50 tonne threshold?Crossing 50 tonnes by 5 brings all 55 into CBAM. In 2026 the certificates cost 210 euros; the fixed compliance cost, 15,000 illustrative, is what makes the cliff.
• What a CBAM certificate buffer costs to holdCarry and protection are both linear in the buffer, so the break-even probability is the same at 5 per cent and at 30. And 2027 costs exactly twice 2026.
• How do you calculate AIFMD leverage: gross vs commitment method?Exposure over NAV, twice. A 250 million loan fund is at 216.0 per cent gross and 174.0 per cent commitment, 160.0 once its covered subscription line is excluded.

Reading guide: regulation, compliance and banking → · All 681 articles →

If this book helped, or didn’t, a few lines on Amazon are worth more than they look: they are what the next reader goes on. Write a review. The workbook stays free either way.