Tunley Environmental’s Dr Alejandra Zazueta Lopez looks at how non-EU-based cement producers can prepare effectively for the incoming live phase of the EU’s Carbon Border Adjustment Mechanism (CBAM).
The Carbon Border Adjustment Mechanism (CBAM) is the European Union’s landmark policy to prevent carbon leakage and promote global decarbonisation. As the EU tightens its climate goals under the European Green Deal, CBAM aims to ensure that imported goods are subject to the same carbon costs as those produced within the EU.
Cement producers that import into the EU are already subject to CBAM reporting requirements. This is because the transitional phase of CBAM began in October 2023. It requires importers to submit quarterly reports on the embodied emissions of their imports.
By 2026, full compliance will be enforced, including the purchasing of CBAM certificates based on verified emissions. As companies gear up for this new regulatory landscape, accurate and high-quality carbon data is essential. Here’s a clear guide that shows organisations how to collect high quality data for CBAM compliance.
1 Understanding CBAM obligations
During the transitional phase, importers must submit CBAM reports every quarter via the EU’s CBAM Transitional Registry. Each report must include:
- Total embedded emissions (both direct and indirect) per tonne of imported cement;
- Production site details of non-EU suppliers;
- Methodologies used to calculate emissions;
- Verification status - verification is optional in the transitional phase but required later.
Knowing exactly what to report and by when helps cement producers to prioritise data collection and supplier engagement.
2 Mapping the supply chain
CBAM focuses not just on the final imported cement products, but on how and where they were produced. Producers need to map their supply chain for all products within the CBAM scope. This includes:
- Identifying non-EU suppliers and production facilities;
- Understanding the production processes involved (especially energy-intensive steps);
- Collecting supplier contact information and establishing communication channels.
This mapping exercise is the foundation for gathering reliable primary data from your suppliers, which is preferred over using default values.
3 Collect primary emissions data
Primary data is key. Producers should start to collect actual emissions data from suppliers, including:
- Direct emissions from production (e.g. combustion of fossil fuels on-site);
- Indirect emissions from electricity consumption (based on the regional or national grid mix).
Collecting data from suppliers is one of the biggest challenges and probably the most time-consuming task for CBAM declaration. Creating a strong communication channel with suppliers is essential to reduce uncertainties and avoid last minute hassles. When requesting data, producers should ensure that suppliers are aware of the EU-approved calculation methods, such as those in the EU’s CBAM Implementing Regulation or ISO standards. Suppliers should be encouraged to maintain documentation and logs to support future audits.
4 Apply the correct methodology
CBAM requires that emissions be calculated using specific methodologies. These should:
- Align with EU guidance (e.g.: EU ETS Monitoring and Reporting Regulation);
- Include all relevant emission sources and account for CO2 content in raw materials where applicable;
- Distinguish between direct and indirect emissions clearly.
Use the official CBAM communication templates and tools where possible. These are designed to help importers ensure consistency and comparability across submissions. Some businesses may choose to use Life Cycle Assessment (LCA) or carbon accounting data, to accurately report their emissions and identify potential reduction opportunities
when possible.
5 Prepare for verification
Although third-party verification is not mandatory during the transitional phase (2023 – 2025), preparing data as if it were being audited is a smart move. To do this:
- Keep source documents from suppliers (e.g.: meter readings, fuel receipts);
- Record calculation steps and assumptions clearly;
- Organise data in a format that can be easily reviewed and checked.
From 2026 onwards, emissions data must be verified by an accredited verifier. Starting early helps build confidence in the processes and avoid future penalties.
6 Create an internal CBAM reporting system
Consistency and accuracy in reporting will require internal systems that support:
- Quarterly data collection and aggregation;
- Data validation workflows;
- Version control and audit trails.
If the producer already reports emissions under frameworks like Carbon Disclosure Project (CDP), Greenhouse Gas (GHG) Protocol, or European Union Emissions Trading System (EU ETS), it may be able to adapt these systems. However, CBAM’s focus on product-level emissions and import volumes means new processes and coordination with procurement teams will be needed.
Concluding remarks
CBAM marks a fundamental shift in how international trade interacts with climate policy. While the compliance requirements may seem complex, they also present an opportunity for businesses to gain better visibility into their supply chains and take a proactive role in CO2 emissions reduction strategies. By implementing sustainable practices along their supply chain, businesses can become more resilient to carbon border taxes.
By starting early, building strong data quality practices, and fostering transparent supplier relationships, organisations can meet CBAM audit requirements and also position themselves as leaders in sustainable cement production. CBAM represents an innovative opportunity to work towards decarbonisation. Through a joint effort with businesses and their international suppliers, it is possible to make an important positive impact on climate change mitigation.
About Tunley Environmental
Tunley Environmental helps organisations to prepare and verify their CO2 data for CBAM compliance, to understand their supply chains and to identify opportunities for CO2 emissions reductions.
