Embedded emissions

Embedded emissions are the greenhouse gases released in producing a good, expressed per tonne of product. They split into two parts. Direct emissions come from the production process itself and the heat consumed on site. Indirect emissions come from the electricity used in production, wherever that electricity was generated.

Which part counts depends on the sector. For some sectors only direct emissions are in scope for the certificate obligation; for others indirect emissions are reported too. The declaration keeps the two figures separate so the correct rules can be applied to each.

Emissions can be reported using actual values, measured or calculated from the producer’s own monitored data, or default values published by the Commission for each good and country of origin. Which route applies, what actual data requires, and how the two compare on cost is set out in Default values vs actual emissions.

The default values live in the Commission’s implementing acts. Annex I to Implementing Regulation (EU) 2025/2621 publishes the default values applied per good and country of origin when actual data is not available, except for electricity, which Annex III covers. The phase-in that scales the certificate obligation through the definitive period is set elsewhere: Article 10a(1a) of Directive 2003/87/EC, as amended by Directive (EU) 2023/959, defines the annual CBAM factor, and the certificate obligation is what remains after that free-allocation adjustment. Regulation (EU) 2023/956 coordinates it at Article 31, and Implementing Regulation (EU) 2025/2620 operationalises it.

For each good, the XML declaration carries the embedded emissions per tonne and in total, split into direct and indirect, together with the production route, the determination method (actual or default), and any carbon price paid at origin that is eligible for deduction. The method flag matters: it tells the Registry which evidence standard applies to the figure.

Getting these fields internally consistent (emissions, route, method, and supporting documentation all agreeing) is what separates a file your importer can use from one they cannot.