Calculation Methodology

Regulatory basis

CBAMable's calculations are grounded in the primary EU CBAM legislation and its implementing measures. The core framework comprises:

Where implementing regulations are revised between reporting periods, CBAMable updates its default value tables accordingly. The applicable regulation version for each export pack is recorded in the pack metadata.

CBAMable does not provide legal interpretation of these regulations. Where classification or methodology questions arise, users should seek guidance from a qualified customs adviser or the EU CBAM helpdesk.

Covered goods

CBAMable covers all product categories listed in Annex I to Regulation (EU) 2023/956. These are identified by their Combined Nomenclature (CN) codes as set out in the regulation and updated by subsequent Commission measures.

Goods not within Annex I are out of scope and will not appear in a CBAMable export pack, even if they appear in the same invoice or shipment document as in-scope goods.

CN code classification is based on the codes as presented in the source document. CBAMable does not provide tariff classification advice. Where CN codes are absent or ambiguous, the system flags the line for manual review rather than assuming a classification.

Scope threshold (de minimis)

Regulation (EU) 2025/2083 (in force 20 October 2025), amending Regulation (EU) 2023/956, exempts importers whose cumulative imports of CBAM goods do not exceed 50 tonnes net mass per calendar year from CBAM authorisation, declaration and certificate obligations. The threshold covers cement, fertilisers, iron & steel and aluminium; it does not apply to hydrogen or electricity, which remain in scope regardless of mass. It replaces the former EUR 150 per-consignment exemption.

CBAMable tracks the cumulative recorded net mass of in-scope goods per client per calendar year against this threshold and shows the headroom remaining. This view is based only on records held in CBAMable: the legal threshold counts all of the importer's CBAM-goods imports into the EU, so the figure must be confirmed against the client's complete import records before any reliance is placed on the exemption. Importers expecting to exceed the threshold should seek authorised CBAM declarant status before exceeding it.

UK CBAM scope (from 1 January 2027)

UK CBAM scope is assessed separately from EU scope. From 1 January 2027 the UK regime covers aluminium, cement, fertilisers, hydrogen and iron & steel; glass and ceramics are not in scope from 2027, certain scrap goods are excluded by commodity code, and electricity is not a UK CBAM sector. UK CBAM covers direct emissions only at launch, and the UK operates a value-based registration threshold (£50,000 of CBAM goods over a rolling 12-month period) administered by HMRC — a different mechanism from the EU mass-based threshold above. CBAMable presents each goods line's EU and UK scope determination side by side, with the reason and a confidence rating.

The EU CBAM export pack

The EU CBAM export pack is a structured reference document generated from the importer's or broker's trade data. It is designed to support the CBAM declarant's obligations under Article 35 of Regulation (EU) 2023/956 and to facilitate evidence requests to third-country suppliers.

What the export pack contains

• Identified CBAM-scope goods extracted from the source document, with their CN codes and descriptions
• Country of origin for each consignment line
• Declared quantity (net mass, or MWh for electricity), drawn from the source document
• Applicable embedded emissions per unit — calculated using default values where supplier-verified actuals are unavailable
• Total estimated embedded emissions for the consignment, expressed in tonnes of CO₂ equivalent (tCO₂e)
• Free allocation offset applied (if any), with the basis stated
• A summary of evidence received from the supplier, if collected via the CBAMable supplier portal
• Recommended next actions — including any lines flagged as requiring supplier evidence or manual review

What the export pack is not

The pack does not constitute professional customs, legal or carbon accounting advice. It is a structured record intended to assist the declarant in assembling and reviewing the information required for their own reporting obligations.

Calculation approach

Embedded emissions are calculated at the level of each CBAM good identified in the uploaded document. The calculation follows the methodology set out in the applicable implementing regulation for the reporting period.

• 1
  Embedded emissions defined Embedded emissions are the greenhouse gas emissions (expressed in tCO₂e) arising from the production process of the good, covering both direct process emissions and, where the implementing regulation requires, indirect emissions from electricity consumption. The scope of direct and indirect emissions varies by sector and is defined in Annex III to Regulation (EU) 2023/956 and the relevant delegated acts.
• 2
  Quantity basis Embedded emissions are calculated per tonne of net mass for solid goods, and per MWh for electricity. Quantities are taken from the declared figures in the source document. Where the source document states gross mass only, a flag is raised for manual review.
• 3
  Default or actual emissions applied Where the supplier has not provided verified actual emission data, CBAMable applies the applicable default value for the good's CN code and country of origin (see Section 5). Where verified actual data has been received and recorded via the supplier portal, the actual figure is used instead of the default.
• 4
  Carbon price paid in the country of origin (Article 9) Under Article 9 of Regulation (EU) 2023/956, a carbon price effectively paid in the country of origin may reduce the CBAM obligation, subject to evidence and verification requirements. CBAMable records the amount, currency, pricing instrument, period covered and supporting evidence, and applies the resulting credit to the indicative estimate only when the value is evidenced and applied, or explicitly applied by the broker for review (and labelled as such) — never silently. Non-EUR amounts require a recorded exchange rate with its date and source. Credits are capped so the indicative figure never goes below zero, and every calculation step is shown in plain English.
• 5
  Free allocation / CBAM factor The adjustment reflecting EU ETS free allocation (which phases out between 2026 and 2034) is shown separately from the Article 9 credit. It is not applied unless explicitly configured: the broker may enter a CBAM-factor percentage or a manual amount, and either is clearly labelled as an assumption applied for broker/declarant review. Where nothing is configured, the calculation takes the more conservative position and shows the unadjusted figure.
• 6
  Aggregation and snapshot Embedded emissions are calculated per line item and aggregated to give a total for the consignment. Where a single invoice contains multiple CBAM-scope goods from different origin countries, each line is calculated and presented separately. Every generated report captures the values, assumptions, reference-data version and Article 9 treatment used at the time of generation — issued reports never recalculate silently when assumptions change later.

Default emission values

Default values are published by the European Commission and apply where a supplier has not provided verified actual emission data. CBAMable draws default values from:

Default values are set by the Commission at a level intended to be above the average actual emissions for each sector. This is a deliberate policy design: it creates an incentive for importers and their suppliers to provide verified actual figures, which in most cases will result in a lower CBAM obligation.

Default values are denominated in tCO₂e per tonne of good (or per MWh for electricity) and vary by CN subheading and, in some sectors, by origin country or production route. CBAMable applies the most specific default available for the identified good. Where a default is not available at subheading level, the sector-level default is applied and the line is flagged.

Supplier actual data

CBAMable includes a supplier evidence portal that allows importers and brokers to request verified actual emission data directly from their third-country suppliers. Where a supplier provides this data, it is recorded against the relevant consignment line and used in place of the applicable default value.

Supplier-submitted data is received and stored by CBAMable. It is not independently verified by CBAMable — verification of actual emission data remains the responsibility of the declarant, consistent with Article 4 and Annex III of Regulation (EU) 2023/956 and the requirements of the applicable implementing regulation.

The export pack clearly identifies whether each line uses a default value or supplier-provided actual data, and records the date the supplier data was received. This audit trail supports the declarant's record-keeping obligations.

Limitations

Users should be aware of the following material limitations:

Scope of service

CBAMable is a data organisation and reporting preparation tool. It is not an authorised CBAM declarant, accredited verifier, customs agent or legal adviser. Export packs are preparatory documents only.

Classification

CN code identification is based on the codes as presented in the source document. CBAMable does not provide independent tariff classification advice. Any classification uncertainty should be referred to a qualified customs adviser before submission.

Default values are estimates

Where supplier actual data is unavailable, default values represent regulatory estimates, not independently verified production-specific emissions. The resulting embedded emissions figure may differ materially from the supplier's actual emissions.

Supplier data is unverified

CBAMable records supplier-provided actual data but does not verify it. The declarant bears responsibility for the accuracy of data submitted to the CBAM Registry.

Evolving legislation

CBAM legislation and its implementing measures are subject to revision. Default values, in-scope goods and reporting methodologies may change between reporting periods. CBAMable updates its tables as new measures are published, but users should verify the applicable regulation version for each reporting period.

No filing service

CBAMable does not submit CBAM declarations to the EU CBAM Registry on behalf of users. Declarations must be filed by an authorised CBAM declarant using the Registry directly.

Contact & further guidance

For technical questions about CBAMable's methodology or calculations, contact support@cbamable.com.

For official guidance on CBAM obligations, reporting and the Registry, refer to the European Commission's published resources:

• EU CBAM official information: taxation-customs.ec.europa.eu
• CBAM Transitional Registry: cbam.ec.europa.eu

For customs classification advice, origin determination or declarant authorisation, consult a qualified customs broker or adviser.