CBAM embedded-emissions data calculated from primary production-process evidence rather than default proxy values.
Actual emissions are the higher-evidence alternative to default values. They matter because the supplier can support the reported CBAM quantity with installation and process data instead of relying on conservative fallback values. It is harder to obtain from suppliers than default data because it depends on monitoring and calculation capability.
In CBAM, actual emissions must be calculated according to the relevant methods, including Annex IV context, and supported by production-process evidence. The term should remain separate from voluntary product-footprint estimates and generic supplier climate claims.
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism
the emissions calculated based on primary data from the production processes of goods and from the production of electricity consumed during those processes as determined in accordance with the methods set out in Annex IV;
Reference: Article 3, point 28
Reviewed public draft page. Aligns with CBAM high-priority policy: source-bound method boundaries, concrete implementation records, and evidence/cost-focused commentary. Commission Implementing Regulation (EU) 2023/1773 adds transitional reporting and calculation context rather than a second formal definition.
CBAM and product carbon footprint (under ESPR or the Battery Regulation) both quantify emissions associated with goods, but use different methodologies, scope boundaries, and regulatory purposes. CBAM focuses on production-process emissions at installation level; product carbon footprinting uses lifecycle thinking from raw material to end-of-life. A company may need to run both calculations for the same goods, and the numbers will differ — this is expected and not a compliance error.
Commission Implementing Regulation (EU) 2023/1773 Article 4(1) anchors actual emissions evidence in monitoring methods based on source streams, activity data, calculation factors, emission sources, and continuous measurement. Article 4(3) separately allowed temporary use of other methods where required information was unavailable, preserving the distinction between primary-data actual emissions and fallback/default approaches.
Implementation records should capture primary data, calculation method, monitoring period, verification status, installation, production process, goods scope, measurement/calculation file, responsible operator, and the default-value replacement decision if actual data becomes available later.
Actual emissions are a trust-and-evidence term. Reported values need to be linked to source data, methods, periods, and goods records so importers can distinguish validated supplier evidence from a number typed into a reporting field.
Transitional-period reporting and calculation rules that support this CBAM term without replacing the formal Regulation (EU) 2023/956 definition.
Open reference