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Cement and CBAM.

Clinker carries almost all of the sector’s embedded emissions, and roughly two thirds of them come from the calcination reaction itself — not from the fuel. That single fact shapes the whole evidence file.

Scope

What CBAM covers in this sector.

CN codes2507 00 80 · 2523 10 00 · 2523 21 00 · 2523 29 00 · 2523 30 00 · 2523 90 00
Covered goodsCalcined kaolinic clays, cement clinker, white and other Portland cement, aluminous cement and other hydraulic cements.
Emissions in scopeDirect and indirect emissions. Cement is not listed in Annex II, so purchased electricity counts.
Relevant precursorsCement clinker is the precursor for cements. Calcined clay is a precursor where blended cements are produced.
Transcribed from Annex I and Annex II to Regulation (EU) 2023/956; checked 01 September 2026. The Official Journal text and the classification declared to customs govern. Sector guidance published on 14 August 2026 is available from the European Commission.
Production routes

The route decides the number.

  • Dry-process kiln with preheater and precalciner — the dominant route, and the one most guidance examples assume.
  • Clinker purchased from another installation and ground on site — the embedded emissions of the purchased clinker come with it.
  • Blended cements using calcined clay, slag or fly ash — the clinker factor becomes the number that matters most.
Hardest data points

Three places this sector fails verification.

Data point 1

Splitting process CO₂ from combustion CO₂. Calcination emissions come from the raw meal, not the fuel, and need the carbonate content of the raw material — not an assumed factor.

Data point 2

Clinker factor per cement type. Production records usually track cement tonnes, while the emissions live in the clinker; the conversion has to be evidenced per product, not per plant.

Data point 3

Alternative fuels. Waste-derived fuel changes the emission factor and the biomass fraction, and the sampling frequency behind it is exactly what a verifier tests.

CBAM accreditation status: our application has been formally accepted by ACCREDIA and the assessment is underway. Accredited CBAM verification will be offered only after formal accreditation is granted and within the approved scope. Full status record

Build the file that has to survive verification

Describe the claim — not the service.

Tell us what must be relied on, who will rely on it and by what date. We will confirm the correct programme, evidence requirement and responsible entity — or tell you it is outside our scope.