CBAM for aluminium and cement: obligations and calculation differences
Clinker ratio and indirect emissions in cement; scrap, PFCs and precursor data in aluminium. How CBAM embedded emissions work in both sectors, the default values for Türkiye, and what to prepare now.
CBAM obligations for aluminium and cement share one framework, but the calculation splits in two. Cement counts both direct emissions and indirect emissions from electricity, and the result is tied to the amount of clinker in the product. Aluminium counts direct emissions only, so what matters is the production route (electrolysis or scrap melting) and the data on purchased unwrought aluminium. Both sectors share one exposure: without verified actual data, the EU importer falls back on high default values.
This guide is based on the European Commission's sector guidance for cement and aluminium of 14 August 2026 (Guidance 5A and 5E), the methodology regulation (2025/2547) and the default values regulation (2025/2621, as corrected by 2026/1740). New to the mechanism? Start with our CBAM overview; iron and steel are covered in our steel guide.
Cement and aluminium under CBAM at a glance
| Topic | Cement | Aluminium |
|---|---|---|
| Emissions counted | Direct + indirect (electricity) | Direct only |
| Calculation unit | Tonne of clinker content (cement); tonne of product (clinker, calcined clay, aluminous cement) | Tonne of product |
| Possible precursors | Clinker, calcined clay if used | Unwrought aluminium, other aluminium products |
| Inputs with zero embedded emissions | Gypsum, slag, fly ash, natural pozzolana | Scrap, anodes, alumina |
| Sector-specific difficulty | Clinker-to-cement ratio, process emissions | PFCs, scrap share, precursor data |
| Extra data for the importer | Clinker content of the cement | Scrap per tonne, pre-consumer scrap share, alloy content |
Which cement goods fall under CBAM?
| Category | CN / TARIC code | Note |
|---|---|---|
| Calcined clay | 2507 00 80 80 | Non-calcined clay is out of scope |
| Cement clinker | 2523 10 00 | White (…10) and other/grey (…90) calculated separately |
| Cement | 2523 21 00, 2523 29 00, 2523 90 00 | Complex good; white and grey separate |
| Aluminous cement | 2523 30 00 | Simple good, no precursors |
How are embedded emissions in cement calculated?
The unit for cement is not the tonne of cement but the tonne of clinker it contains. Direct and indirect emissions are first established per tonne of clinker, then multiplied by the clinker content of the product. Slag, fly ash and natural pozzolana therefore pull the figure down directly: they are not CBAM precursors and carry zero embedded emissions in this calculation.
The Commission's worked example has 0.8265 t direct and, including grinding, 0.0967 t indirect emissions per tonne of clinker (0.9232 t CO₂e in total). Using the same values, the effect of the clinker ratio looks like this:
| Clinker ratio | Embedded emissions per tonne of cement | Status |
|---|---|---|
| 0.95 | 0.8771 t CO₂e | Commission example (Portland cement) |
| 0.75 | 0.6924 t CO₂e | Our hypothetical, blended cement |
The example uses another country's electricity factor, so this is not the figure for a plant in Türkiye or anywhere else; it only shows the method. If you sell custom-made compositions, a clinker content declaration is needed for each consignment.
Process emissions
Most clinker emissions come from the thermal decomposition of limestone. Two equivalent methods exist: input-based Method A (carbonates in the raw meal) and output-based Method B (clinker produced). Under Method B, a standard factor of 0.525 t CO₂/t clinker is the minimum requirement; laboratory analysis is the recommended improvement. Emissions from discarded bypass and kiln dust are added, with a minimum factor of 0.525 t CO₂/t dust.
Electricity and alternative fuels
- Indirect emissions: MWh consumed multiplied by the country default factor. An actual factor requires evidence of either a direct technical link to the power plant or a valid power purchase agreement, and that plant's emissions must be monitored under the same rules and verified.
- Waste-derived fuels: the biodegradable share of municipal waste is zero-rated while the fossil share counts. If you cannot evidence the biomass share, you cannot claim the benefit.
If you buy or sell clinker
For a grinding plant that buys clinker, clinker is a precursor. If the supplier does not provide verified data for the same reporting period, the clinker default value plus the mark-up applies. Precursors are tracked separately by supplier installation and production year. If all your clinker goes into your own mill, clinker and cement can be monitored as one joint process; selling part of the clinker removes that option.
Which aluminium goods are covered?
| Category | CN code | Examples |
|---|---|---|
| Unwrought aluminium | 7601 | Ingots, billets, slabs |
| Aluminium products | 7603–7608, 7609 00, 7610–7614, 7616 | Profiles, wire, sheet, foil, tubes, windows and doors, tanks, cables, other articles |
Scrap (7602 00) and certain household articles under 7615 are excluded.
Where do aluminium emissions come from?
In the definitive period, electricity emissions are not added to aluminium's embedded emissions. What remains depends on the route:
- Primary (electrolysis): CO₂ from anode consumption, furnace fuels, measurable heat and flue gas cleaning. CF₄ and C₂F₆ (PFCs) formed during anode effects are also monitored and converted to CO₂ equivalent.
- Secondary (scrap melting): fuels for drying, pre-heating, de-coating and de-oiling, melting, casting and treating skimmings. There are no PFC emissions on this route. Scrap, pre-consumer or post-consumer, is a raw material with zero embedded emissions.
- Forming (extrusion, rolling, forging, drawing): combustion and flue gas cleaning. Annealing and surface preparation are inside the boundary; cutting, welding and finishing are outside it.
Anode production and alumina sit outside the boundary and are not precursors. You may keep monitoring electricity for internal purposes, but it does not enter the CBAM figure.
For extruders and rollers, precursor data is the real issue
At a plant that buys billet or slab and forms it, the plant's own fuel emissions are often the smaller share; purchased unwrought aluminium largely determines the result. Primary and secondary metal are treated separately where the data is known. Without verified supplier data, default values apply.
Installations carrying out only excluded steps such as cutting still need verification, and a brief monitoring plan, if they want to use actual values. The Commission points out a detail that is easy to miss: precursor mass is taken before cutting, so emissions per tonne of product rise even though the cutting itself is not reported.
Aluminium parameters to pass to the importer
- Tonnes of scrap used per tonne of product
- Share of that scrap that is pre-consumer
- Total alloy percentage, if elements other than aluminium exceed 1%
Alloying elements that are not CBAM precursors are excluded from the mass and embedded emissions of the good. These records usually sit with the quality team, so the people doing the emissions calculation need access to them.
How large is the gap between default and actual values?
In the corrected default values, the Türkiye rows for grey clinker and grey cement are empty, so the "other countries and territories" row applies. A 10% mark-up is added for 2026 (20% in 2027, 30% from 2028).
| Good | Default (t CO₂e/t good) | With 10% mark-up | Gross cost at €82.32/t |
|---|---|---|---|
| Grey Portland cement (2523 29 00), other countries | 1.440 | 1.584 | ≈ €130 |
| Aluminous cement (2523 30 00), Türkiye | 1.950 | 2.145 | ≈ €177 |
| Unwrought aluminium (7601), Türkiye | 1.700 | 1.870 | ≈ €154 |
| Aluminium profiles (7604 10 90), Türkiye | 3.741 | 4.115 | ≈ €339 |
The last column is a rough per-tonne comparison at the Q3 2026 certificate price (€82.32), before the free allocation adjustment and any carbon price paid, so the actual liability is lower. The Commission example of 0.8771 t comes to about €72 at the same price, a gap of about €58 per tonne of cement against the default. That example is not data from a Turkish plant, but it shows the order of magnitude. Default values will be revised by 2027 at the latest, so this table is not permanent.
How does the Turkish ETS affect these sectors?
Cement and aluminium are among the five sectors of the Turkish ETS pilot phase, which covers category B and C installations. An installation in scope will need its fuel and production data for both CBAM and the ETS. For the details, and the current uncertainty over CBAM deductions, see our Turkey ETS guide.
What should producers and importers do now?
- List goods sold to the EU by CN code; keep white and grey cement, and primary and secondary aluminium, apart.
- Define installation boundaries and production processes. If you sell clinker or intermediates, a joint process is not available.
- Record clinker content per cement product, and scrap and alloy data for aluminium, routinely.
- Ask clinker, billet and slab suppliers for verified data by installation and production year.
- For cement, meter electricity by process and assemble PPA evidence if you have one.
- Write the monitoring plan and talk to a verifier early. For timing and report content, see our CBAM report guide.
To see all of these points with their dates on one page, use our CBAM and Turkish ETS readiness checklist.
If you import from Türkiye, ask suppliers now whether they will have verified installation data in time; our CBAM Turkey page explains how suppliers can provide it.
Conclusion
In cement the gains lie in the clinker ratio and fuel records; in aluminium, in scrap share and precursor data. In both, the main risk is not a wrong formula but data that is not ready, or not verifiable, in time.
Carbonet is CBAM and carbon footprint software developed by LNA Soft in Izmir, Türkiye. It calculates precursor chains such as clinker to cement using the EU method, tracks precursors by supplier and year, and produces the per-good embedded emissions your importer needs. See CBAM embedded emissions calculation for details. To try it with your own goods, request a demo or write to info@carbonet.com.tr or WhatsApp +90 533 368 05 99.
Sources: European Commission Guidance 3, 5A and 5E (August 2026); Implementing Regulations (EU) 2025/2547 and 2025/2621 (as corrected by 2026/1740); Commission CBAM certificate price page. This article is general information, not legal advice.
Frequently asked questions
Do electricity emissions count for cement under CBAM?
Yes. Cement is not listed in Annex II of the CBAM Regulation, so indirect emissions from electricity count alongside direct emissions in the definitive period. MWh consumed are multiplied by the country default factor; an actual factor requires a direct technical link or a valid PPA, with verified plant data.
Do electricity emissions count for aluminium?
No. Aluminium goods are listed in Annex II, so only direct emissions enter embedded emissions from 2026. Indirect emissions were reported separately during the transitional period. You can keep monitoring electricity for internal purposes.
Does recycled aluminium have zero embedded emissions?
No, only the scrap itself is zero-rated. Fuels used for melting, pre-heating, de-coating and de-oiling, casting and treating skimmings still count. Unwrought aluminium added from other sources counts as a precursor. The secondary route has no PFC emissions.
Why do blended cements come out lower under CBAM?
The unit for cement is the clinker it contains. Slag, fly ash and natural pozzolana are not CBAM precursors and carry zero embedded emissions in the calculation. As the clinker ratio falls, embedded emissions per tonne of cement fall in proportion.
What is the default value for grey cement from Türkiye?
In the corrected table the Türkiye rows for grey clinker and grey cement are empty, so the other countries row applies. For grey Portland cement this is 1.440 t CO₂e/t, or 1.584 t in 2026 with the 10% mark-up. Default values are due to be revised by 2027 at the latest.
Does an aluminium plant that only cuts goods need CBAM data?
Cutting, welding and finishing are outside the system boundary, but a plant that wants to use actual values still needs verification and a brief monitoring plan. Precursor mass is taken before cutting, so emissions per tonne of product rise.