CBAM emissions released by the relevant production processes of covered goods, distinct from facility-wide or corporate emissions totals.
Direct emissions define the process boundary inside CBAM embedded-emissions work. The key task is to separate emissions generated by the relevant production process from broader facility, corporate, or lifecycle carbon data.
CBAM direct-emissions language is anchored to production processes of goods. That makes it narrower than generic Scope 1 accounting and more specific than facility-wide climate reporting.
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism
emissions from the production processes of goods, including emissions from the production of heating and cooling that is consumed during the production processes, irrespective of the location of the production of the heating or cooling;
Reference: Article 3, point 21
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.
Commission Implementing Regulation (EU) 2023/1773 Article 3(2)(d) requires specific embedded direct emissions to be determined by converting the attributed direct emissions of the production processes into emissions specific of the goods expressed as CO2e per tonne. This keeps direct emissions tied to production-process attribution rather than a broad corporate Scope 1 inventory.
Implementation records should capture production-process boundary, emission source, installation record, calculation file, monitoring period, fuel/input data, heating/cooling treatment, goods line, and link to the embedded-emissions calculation.
Direct emissions are a process-boundary term and boundary-control term. Evidence must be linked to the production step and installation record so emissions data can be reconciled to the goods being imported instead of drifting into a broad facility narrative.
Transitional-period reporting and calculation rules that support this CBAM term without replacing the formal Regulation (EU) 2023/956 definition.
Open reference