Cement CBAM: one plant's
late data blocks all.
Each non-EU cement plant must supply schema-valid emissions data, including the clinker-to-cement ratio.
ILLUSTRATIVE EF: PORTLAND CEMENT
DEFAULT-VALUE MARKUP 2026
PHASE-IN 2026
CBAM CERTIFICATE PRICE · Q2 2026
What the XML must contain
Default-value exposure
What default values mean for a cement declaration.
Where a plant cannot evidence actual embedded emissions, the declaration falls back to the default values published for the goods' country of origin. Those defaults carry a statutory mark-up of +10% in 2026, applied to the embedded emissions declared, not charged as a fixed fee.
Certificates are surrendered against the declared emissions after the free-allocation adjustment, which phases in from 2026. What that costs turns on the origin-specific default value for each CN code and the clinker ratio behind it, together with the certificate price published for the quarter, currently €75.28 per tCO₂e for Q2 2026. Declaring the actual clinker content and plant emissions removes the mark-up. Default emission values are origin-specific per the Annex to Regulation (EU) 2025/2621; CBAM scope per Annex I to Regulation (EU) 2023/956.
How Carbon Mandate solves it
One dashboard for every cement supplier on your declaration.
Frequently asked
Cement CBAM, answered.
Why is CBAM harder for cement importers than a single calculation?
Chapter 25 cement (Portland cement, clinker and hydraulic cements) is sourced from non-EU plants whose embedded emissions are dominated by the process emissions of clinker calcination, and the clinker-to-cement ratio differs by product and plant. Each installation must supply schema-valid embedded-emissions data, with the actual clinker content declared, before the annual declaration can be filed. A single rejected or late XML from one plant holds up the whole declaration set. The coordination load — not any one calculation — is the hard part.
What happens if a cement supplier cannot provide actual emissions data?
Where actual data is unavailable, the declaration falls back to default values, which carry a phased markup: +10% in 2026. On an illustrative Portland-cement embedded factor of 0.843 tCO₂e per tonne, that uplift is paid in certificates. Because clinker is a CBAM precursor, declaring the actual clinker ratio and plant emissions removes the markup.
Does Carbon Mandate file my CBAM declaration with the EU Registry?
No. Carbon Mandate is a preparer, not a filer. We check every incoming supplier XML against the EU CBAM schema, coordinate the supplier pipeline, and hand your filing team an audit-ready evidence pack. You remain the declarant of record and file with the EU Registry yourself.