Commission Implementing Regulation (EU) 2025/2547 of 10 December 2025 laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goods

For the purposes of this Regulation, the definitions laid down in Article 1 of Commission Implementing Regulation (EU) 2025/2546 and Article 1 of Commission Delegated Regulation (EU) 2025/2551 apply. The following definitions also apply: (1) ‘functional unit’ means the reference unit used for the calculation of embedded emissions in goods; (2) ‘activity level’ means the quantity of goods to which the same functional unit applies that are produced within the system boundaries of a production process during a reporting period; (3) ‘system boundary’ means the group of chemical or physical processes included in the calculation of embedded emissions of goods under the same aggregated goods category; (4) ‘aggregated goods categories’ means aggregated goods categories pursuant to Table 1 of point 2 of Annex I; (5) ‘reporting period’ means the period corresponding to the calendar year during which the good was produced and used by the authorised CBAM declarant as reference for the determination of embedded emissions; (6) ‘production route’ means a specific technology used in a production process to produce goods; (7) ‘precursor’ means any input material into a production process included in the list of goods set out in Annex I to Regulation (EU) 2023/956; (8) ‘source stream’ means either of the following: (a) a specific fuel type, raw material or product giving rise to emissions of relevant greenhouse gases at one or more emission sources as a result of its consumption or production; (b) a specific fuel type, raw material or product containing carbon and included in the calculation of greenhouse gas emissions using a mass balance method; (9) ‘emission source’ means a separately identifiable part of an installation or a process within an installation, from which relevant greenhouse gases are emitted; (10) ‘calculation factors’ means net calorific value, emission factor, preliminary emission factor, oxidation factor, conversion factor, carbon content or biomass fraction; (11) ‘measurement system’ means a complete set of measuring instruments and other equipment used to determine variables for the monitoring and calculation of emissions; (12) ‘activity data’ means the amount of fuels or materials consumed or produced by a process relevant for the calculation-based methodology, expressed in terajoules, mass in tonnes or, for gases, volume in normal cubic metres, as appropriate.

Where the embedded emissions are determined based on actual emissions in accordance with Article 7(2), point (a), of Regulation (EU) 2023/956, the rules laid down in this Chapter shall apply.

1 In order to quantify and calculate specific embedded emissions of goods, the processes within an installation that occur within the system boundaries, defined per aggregated goods category in accordance with Annex I, shall be taken into account.

2 The system boundaries shall cover direct emissions, indirect emissions for goods not listed in Annex II to Regulation (EU) 2023/956, and the embedded emissions of any precursor.

1 Operators of an installation shall identify, within the system boundaries of an installation, the production process of goods to which the same functional unit applies. The identification of the production process shall ensure that relevant inputs, outputs and emissions can be monitored in accordance with Annex II and that direct and indirect emissions, where relevant, can be attributed to goods to which a functional unit applies.

2 The quantities of goods produced in tonnes classified under the same CN code shall constitute the functional unit, except for the goods referred to in paragraphs 3, 4 and 5.

3 For electricity, the kWh shall constitute the functional unit.

4 For fertilisers, the following shall constitute the functional unit: (a) for CN codes 28080000, 2814, 3105, the kilograms of nitrogen contained in the goods produced under the respective CN codes; (b) for the CN codes of fertilisers other than the ones listed in point (a), the supplementary units as laid down in Regulation (EEC) No 2658/87 of the goods produced under the respective CN codes.

5 For CN codes 25231000, 25232100, 25232900, 25239000, the tonnes of clinker contained in the goods produced under the respective CN codes shall constitute the functional unit.

6 Where goods to which the same functional unit applies are produced using different production routes within an installation, a single production process shall be used encompassing all production routes.

7 Splitting an installation into different installations, with the result that production routes otherwise pertaining to a single production process are carried out in separate installations, shall only be allowed where the operators demonstrate valid commercial reasons for this split that are related to their economic activity. Commercial reasons shall be considered as valid where circumventing Regulation (EU) 2023/956 is not their main purpose or one of their main purposes.

8 Where goods to which different functional units apply are produced through the same processes, the operators may determine a single multifunctional production process. In that case, attribution rules in accordance with point A.2 of Annex III shall apply. In situations specified in point A.4 of that Annex, the determination of a single multifunctional production process shall be mandatory.

9 Where precursors relevant for complex goods are produced in the same installation as the complex goods, and where the respective precursors are not transferred out for sale or use in other production processes, the production of precursors and complex goods may be covered by a joint production process. In that case, monitoring and calculation of embedded emissions of the precursors and complex goods shall be carried out jointly.

1 Direct emissions of a production process shall be determined in accordance with the monitoring principles and methods laid down in points A and B of Annex II, and by using the monitoring methodologies and rules determined in accordance with point B of that Annex.

2 Where heat flows are involved in the production of a functional unit, the monitoring and calculation rules laid down in point C of Annex II shall be applied.

3 For complex goods, the emissions of the precursors shall be monitored in accordance with the rules set out in point E of Annex II.

4 Indirect emissions shall be determined by monitoring the consumption of electricity in the relevant production process, in accordance with point D of Annex II.

5 For the purpose of paragraphs 1 to 4, operators shall design and implement a monitoring plan containing at least the elements outlined in point A.5 of Annex II.

6 The monitoring plan shall be submitted in English.

The specific embedded emissions of goods shall be determined by attributing direct and, where relevant, indirect emissions of the production processes to the specific goods in accordance with Annex III.

1 For the purpose of determining the actual embedded emissions in a good, the reporting period during which the good was produced shall be determined in accordance with the second subparagraph. Where a good was imported during the year 2026, the reporting period shall be the year 2026. Where the good was imported during another year than 2026, the reporting period shall by default be the calendar year during which the good was imported. However, if there is sufficient evidence to identify the actual time of production, the reporting period shall be the period during which the good was produced.

2 By way of derogation from paragraph 1, the reporting period for electricity imported into the customs territory of the Union shall be the year of import.

1 The elements of evidence demonstrating the fulfilment of the criteria listed in point 5 of Annex IV to Regulation (EU) 2023/956 are provided in point D.2.4 of Annex II to this Regulation.

2 The elements of evidence demonstrating the fulfilment of the criteria listed in point 6 of Annex IV to Regulation (EU) 2023/956 are provided in point D.4.3 of Annex II to this Regulation.

3 For the purpose of demonstrating the fulfilment of the criteria referred to in paragraph 1 of this Article, operators shall indicate in the operator’s emissions report that the criteria laid down in point 5, first subparagraph, point (c), of Annex IV to Regulation (EU) 2023/956 and, where relevant, point 5, first subparagraph, point (b) of that Annex in relation to the direct connection between the installation producing electricity and the Union transmission system, are met. Operators shall provide the verifier with the elements of evidence listed in point D.2.4 of Annex II to this Regulation supporting that indication.

4 For the purpose of demonstrating the fulfilment of the criteria referred to in paragraph 1 of this Article, the operator shall also, in an addendum to the operator’s emissions report created separately for each authorised CBAM declarant who imported electricity from the installation of that operator and who wants to use actual values for that electricity, indicate, for each of those authorised CBAM declarants, that the criteria laid down in point 5, first subparagraph, points (a) and (d), of Annex IV to Regulation (EU) 2023/956, as well as, where relevant, in point 5, first subparagraph, point (b), of that Annex in relation to the lack of physical network congestion, are met. In the addendum for each authorised CBAM declarant, the operator shall also indicate the quantity of electricity imported by the relevant authorised CBAM declarant for which the criteria laid down in point 5 of Annex IV to Regulation (EU) 2023/956 are met, and shall provide the verifier with the relevant elements of evidence listed in point D.2.4 of Annex II to this Regulation supporting that indication.

5 For the purpose of demonstrating the fulfilment of the criteria referred to in paragraph 2 of this Article, operators shall indicate in the operator’s emissions report that the criteria laid down in point 6 of Annex IV to Regulation (EU) 2023/956 are met, and shall provide the verifier with the elements of evidence listed in points D.4.3 of Annex II to this Regulation supporting that indication.

6 The actual embedded emissions of electricity and the actual embedded indirect emissions shall be calculated using the rules laid down in point D of Annex II.

1 Where an installation producing goods listed in Annex I to Regulation (EU) 2023/956 and not listed in Annex II to that Regulation, receives, during a reporting period, electricity from multiple sources, and where actual emissions are reported for such goods, the embedded indirect emissions of the goods shall be determined by default. The default shall be the average of the emission factors of each electricity source, weighted by the share of total electricity consumed in that installation that the electricity received from each source represents.

2 However, where operators provide the verifier with sufficient evidence demonstrating that the installation producing goods not listed in Annex II to Regulation (EU) 2023/956 used, for a given production process, only electricity from one single source, or from a subset of sources, the embedded indirect emissions of goods produced through that production process shall be determined, respectively, based on the emission factor of that single source, or as the average of the emission factors of each relevant electricity source part of the subset, weighted by the share of total electricity consumed in the production of such goods that the electricity received from each source represents.

1 Where the embedded emissions are calculated based on actual emissions, the operators shall prepare an emissions report (‘operator’s emissions report’) and a summary thereof containing at least the information listed in the templates in points 1.1 and 1.2 of Annex IV. Where the embedded emissions of electricity are calculated based on actual emissions, operators shall, in addition, prepare a declarant-specific addendum to the operator’s emissions report containing the information listed in point 1.1.1 of that Annex.

2 Where operators are registered in the CBAM registry pursuant to Article 10 of Regulation (EU) 2023/956, they shall transmit the operator’s emissions report, its summary and, if applicable, the declarant-specific addendum to the verifier via the CBAM registry.

3 Where the operators are not registered in the CBAM registry, they shall transmit the operator’s emissions report, its summary and, if applicable, the declarant-specific addendum to the verifier by means other than via the CBAM registry.

4 The operator’s emissions report shall be submitted in English.

1 Where the embedded emissions in imported goods are determined on the basis of default values in accordance with Article 7(2), point (b), of Regulation (EU) 2023/956, default values laid down in accordance with Annex IV to that Regulation shall be used.

2 Where the embedded emissions of complex goods are determined on the basis of actual values, and the embedded emissions of precursors used in the production of those complex goods are determined on the basis of default values in accordance with Article 15, default values laid down in accordance with Annex IV to Regulation (EU) 2023/956 shall be used for those precursors.

3 For the determination of specific indirect emissions, default values laid down in accordance with Annex IV to Regulation (EU) 2023/956 shall be used, except where actual values can be used in accordance with Article 8.

4 For the determination of embedded direct emissions for electricity imported into the customs territory of the Union, default values laid down in accordance with Annex IV to Regulation (EU) 2023/956 shall be used, except where actual values can be used in accordance with Article 8.

5 The Commission shall conduct a review of the default values by December 2027 at the latest.

The authorised CBAM declarant may use alternative default values in accordance with point 4.2.2, point 4.3 and point 7 of Annex IV to Regulation (EU) 2023/956 where the conditions referred to in point D.2.3 or point D.4.4 of Annex II to this Regulation, or in Annex V to this Regulation, are met.

The default reporting period of a precursor shall be the year of production of the complex good. However, where operators provide the verifier with sufficient evidence to identify the actual time of production, the reporting period shall be the period during which the precursor was produced.

1 Where an installation producing complex goods receives, from another installation, precursors under a given CN code produced during different reporting periods, the embedded emissions of the complex goods shall, for the part of the emissions embedded in the precursors under that CN code, be determined as the weighted average of emissions embedded in the precursors under that CN code produced during those different reporting periods.

2 Where an installation producing complex goods receives precursors under a given CN code from multiple installations, the embedded emissions of the complex goods shall, for the part of the emissions embedded in the precursors under that CN code, by default be determined as the weighted average of emissions embedded in the precursors under that CN code received from the different installations.

3 Where operators provide the verifier with sufficient evidence demonstrating that, out of the precursors under a given CN code received from multiple installations, the installation producing the complex goods used, for a given production process, only precursors from a single installation, or from a subset of installations, the embedded emissions of those precursors used in goods produced through that production process shall be determined, respectively, based on the embedded emissions of the precursors obtained from that single installation, or as the weighted average of emissions embedded in the precursors received from that subset of installations.

The specific embedded emissions for complex goods may be calculated by determining actual emissions for the production processes within the installation producing the complex goods, and default values for one or more precursors of the complex goods.

This Regulation shall enter into force on the third day following that of its publication in the Official Journal of the European Union.