The CBAM emissions quantity attached to covered goods, combining direct production-process emissions and relevant electricity-related indirect emissions under CBAM methods.
Embedded emissions are the core number that connects supplier production data to importer-side CBAM obligations. They turn installation and production-process evidence into the CO2e quantity used for declarations and certificate planning.
CBAM uses embedded emissions to connect installation-level production data, direct emissions, indirect emissions where relevant, and Annex IV calculation methods. The boundary should stay separate from cradle-to-grave LCA, product environmental footprint, and corporate Scope inventories. It is not a cradle-to-grave LCA figure and remains anchored at installation level.
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism
direct emissions released during the production of goods and indirect emissions from the production of electricity that is consumed during the production processes, calculated in accordance with the methods set out in Annex IV and further specified in the implementing acts adopted pursuant to Article 7(7);
Reference: Article 3, point 22
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) links specific embedded emissions to monitoring methods based on source streams, activity data, calculation factors, emission sources, and continuous measurement. This legal-basis layer makes embedded emissions an installation-linked CBAM reporting quantity, not a free-form product LCA method.
Implementation records should capture goods line, CN code, installation, production process, CO2e quantity, direct-emissions component, indirect-emissions component, calculation method, data source, monitoring period, verification status, and links to the supplier evidence file.
Embedded emissions are a supplier-evidence aggregation point. The quantity needs to be traced back to installations, methods, periods, and goods lines so CBAM cost exposure is based on defensible data rather than an unlinked carbon estimate.
Transitional-period reporting and calculation rules that support this CBAM term without replacing the formal Regulation (EU) 2023/956 definition.
Open reference