CBAM Embedded Emissions Worksheet for Imports into the EU
The EU Carbon Border Adjustment Mechanism charges importers of certain carbon-intensive goods for the emissions embedded in them. After the transitional reporting phase ended in 2025, the definitive period requires importers to track embedded emissions per consignment. This worksheet keeps that data in one auditable table.
| CN code | Goods description | Country of origin | CBAM sector | Net mass imported (tonnes) | Direct SEE (tCO2e per tonne) | Indirect SEE (tCO2e per tonne) | Direct tCO2e | Indirect tCO2e | Total tCO2e | |
|---|---|---|---|---|---|---|---|---|---|---|
504 | 0 | 504 | ||||||||
136 | 0 | 136 | ||||||||
444 | 0 | 444 | ||||||||
410 | 30 | 440 | ||||||||
360 | 15 | 375 |
Example emissions values are placeholders, not default values from the EU. Use verified installation data from your supplier, or the default values published by the European Commission where allowed. Which goods need indirect emissions, the reporting period and the certificate rules are set in Regulation (EU) 2023/956 and its implementing acts, so check the current text before filing.
Pull CBAM data from your ERP
Optional: a walk-through of how receipts, CN codes and supplier records can populate this worksheet automatically.
Optional. The tool and every export work without this. No spam.
How to use it
Add one row per CN code and installation or origin. Enter the net mass in tonnes, then the direct specific embedded emissions in tCO2e per tonne obtained from your supplier's emissions report, and the indirect figure only if the goods category requires it. The sheet multiplies mass by each factor and totals the result. Export the table to Excel to support your annual CBAM declaration and your supplier correspondence.
- Group by CN code and production installation
- Request installation-level data from each supplier
- Keep supplier reports and verification evidence on file
- Reconcile mass against customs entries
The method behind it
Embedded emissions are the direct emissions from producing the goods, plus indirect emissions from electricity consumed in production where the regulation requires them, divided by output. CBAM covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, with some downstream products added in scope reviews. Total embedded emissions for a consignment equal mass times specific embedded emissions, and the certificate obligation is then reduced by the free allocation phase-out and any carbon price already paid in the origin country.
Reading the result
The average tCO2e per tonne shows how carbon-intensive your import mix is, and the largest line shows where supplier data quality matters most. A blast furnace route steel coil carries a very different figure from an electric arc furnace coil, so ask each supplier for their actual route. Default values are usually conservative, so verified supplier data often lowers the number.
Common mistakes
Common faults include using the wrong CN code, including indirect emissions for goods where they are not counted, mixing gross and net mass, using one supplier figure for several installations, and reporting data that was never verified. Check the latest guidance on precursors, because the embedded emissions of an input material can add to the final product.
Frequently Asked Questions
What is CBAM?
The Carbon Border Adjustment Mechanism is an EU measure that prices the carbon embedded in selected imported goods so they face a cost comparable to EU producers under the Emissions Trading System. Importers report emissions and surrender certificates.
Which goods are covered?
Cement, electricity, fertilisers, iron and steel, aluminium and hydrogen are covered, identified by CN code, plus certain downstream articles. Always check the annex in the current regulation for the exact list.
What is specific embedded emissions?
It is the tonnes of CO2e emitted per tonne of goods produced, split into direct emissions from the process and indirect emissions from electricity where applicable. Supplier installations calculate it using the monitoring rules in the implementing acts.
Do exporters outside the EU need this?
The legal obligation falls on the EU importer, but they will ask non-EU suppliers for installation emissions data, so exporters benefit from having verified numbers ready for each CN code they ship.
Netray can extract imported tonnage, CN codes and supplier data from your ERP purchasing and receiving records into a CBAM report, read-only and with the query visible.
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