Clinker-traced CBAM
for cement exporters
Clinker, Portland and hydraulic cements — process emissions declared and validated against the live XSD.
Reg (EU) 2023/956 · IR (EU) 2025/2620 Annex II · XSD v2.1
CN CODES IN SCOPE — CHAPTER 25
Annex I to Reg (EU) 2023/956 as amended. Key precursor: cement clinker. Calcination of limestone accounts for approximately 60% of cement sector emissions.
CLINKER RATIO — EMBEDDED EMISSIONS DRIVER
* Lower-clinker blends carry proportionally lower embedded emissions — the declared figure follows the actual clinker-to-cement ratio of the specific product, not a cement-category average.
WHAT THE XML MUST CONTAIN
INSTALLATION DATA
- Installation ID
- Kiln type and production route
- Clinker-to-cement ratio
- Country of origin
- Reporting period
GOODS DATA
- CN code
- Net mass (tonnes)
- Cement type designation
- Unit of measure
- Production method code
EMISSIONS DATA
- Direct process emissions (calcination)
- Direct combustion emissions
- Specific embedded emissions per tonne
- tCO₂e total
CARBON PRICE PAID
- Carbon price paid in country of origin
- Deduction amount
- Rebates applied
- Currency
INGESTION
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VALIDATION
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HANDOVER
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FAQ
Common questions from non-EU exporters.
Is cement clinker a separate CBAM obligation from finished cement?
Yes. Clinker (CN 2523 10 00) is its own CBAM-covered good with its own default emission factor under Annex II. If your plant exports both clinker and finished cement, each requires its own embedded-emissions declaration. Clinker is also a CBAM precursor — its embedded emissions carry forward into the downstream cement XML where clinker is an input.
What if my cement contains supplementary cementitious materials such as fly ash or slag?
Supplementary cementitious materials affect the clinker-to-cement ratio, which directly determines your embedded-emissions calculation. The XML must declare the actual clinker content as a percentage of the finished product. Carbon Mandate extracts the clinker ratio from your production documentation and applies it in the XML generation step.
My importer is asking for an XML — what format does the EU Registry actually accept?
The EU Registry accepts CBAM XML conforming to the DG TAXUD XSD schema. A PDF report or spreadsheet is not an accepted submission format. Carbon Mandate produces a file that validates against the live XSD before transmission so your importer receives an EU-Registry-ready file, not a communication template.
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