What is CBAM, who does it cover?
CBAM (Carbon Border Adjustment Mechanism) is an EU regulation that requires the reporting — and, over time, the pricing — of the embedded carbon emissions generated in producing certain goods imported into the European Union.
Product groups in the initial scope:
- Iron and steel (HS 72–73)
- Aluminium
- Cement
- Fertilisers
- Electricity
- Hydrogen
For companies exporting these products to the EU, CBAM is not optional; it is EU legislation in force. Transitional-period reporting has already begun, and the first official declaration period is planned for 30 September 2027. For emissions that cannot be evidenced, a cost/penalty risk on the order of around €100 per tonne comes into play.
Data list for a CBAM report
The core data you need to collect for a CBAM report to withstand an audit (the "CBAM data list"):
| Category | Required data |
|---|---|
| Company & facility | Company name, facility name/location, production facility identifier |
| Product | Product name, HS/CN code, production route (process) |
| Production | Production volume in the reporting period (tonnes) |
| Energy & fuel | Electricity, natural gas, coal, etc. consumption amounts (kWh, m³, tonnes) |
| Emission factors | Each factor used + its source (official/EU default or measured) |
| Precursor (input) materials | Embedded emissions of purchased semi-finished goods (if any) |
| Evidence | Invoices, meter readings, production records — a document backing each figure |
How are CBAM emissions calculated?
The core logic of the embedded-emissions calculation is simple: activity data × emission factor. That is, how much energy/material was used is multiplied by the relevant official factor.
Simple example (for illustration only)
If a facility consumed 120,000 kWh of electricity and 50,000 kWh equivalent of natural gas in the reporting period, each energy type is multiplied by its own official factor and summed. The result gives that period's direct energy-related emissions; dividing by production volume yields the embedded emissions per product (e.g. tCO₂e / tonne of steel).
Notes for iron and steel exporters
Iron and steel is one of the first and most heavily covered sectors under CBAM; it holds an important share of Türkiye's exports to the EU. Points for iron and steel exporters to watch:
- Check your products under HS 72–73 one by one; each product's production route (e.g. integrated plant vs. electric arc furnace) changes emission intensity significantly.
- If you purchase precursor materials (scrap, pig iron, semi-finished goods), you may also need to account for their embedded emissions.
- The same company reports separately for multiple products and facilities — which is why CBAM is not a one-off but a recurring process.
- Your EU buyer will often request the data from you; a ready, auditable file protects the commercial relationship.
Step by step: from data to PDF report
- Scope check: Compare your product's HS/CN code against the CBAM list.
- Data collection: Fill in the data list above completely; add the source to every row.
- Calculation: Compute embedded emissions via activity × factor; bring it down to a per-product value.
- Review: Flag missing/inconsistent data, then correct it.
- Reporting: Produce an auditable draft CBAM report as a PDF, where each figure appears with its formula and source.
- Verification: The final official verification is carried out by an accredited verifier; your draft speeds up that process.
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Common mistakes
- Writing the emission factor without a source (the most common reason for rejection).
- Skipping precursor material emissions.
- Mixing different facilities/products into a single report.
- Preparing the data once and forgetting the recurring reporting.
- Not keeping evidence documents (invoices, meter readings).
Frequently asked questions
What data is required for a CBAM report?
Company/facility information, product and HS/CN code, production volume, energy-fuel consumption, the emission factors used and their sources, precursor material emissions where applicable, and supporting evidence documents.
How are CBAM emissions calculated?
Embedded emissions = activity data × official emission factor. Every figure is documented with its formula and source.
Are iron and steel exporters within scope?
Yes. Iron and steel (HS 72–73) is in CBAM's initial scope; embedded carbon must be reported when exporting to the EU.
Does Nechh Eco-Report replace the official declaration?
No. Eco-Report is a preparation/draft tool; it does not replace the accredited verifier or the authorised CBAM declarant. It speeds up the process and makes it auditable.