Route-traced CBAM
for hydrogen exporters
Grey, blue or green — your production route declared and validated against the live CBAM XSD.
Reg (EU) 2023/956 · production route grey / blue / green · CN 2804 10 00
THREE PRODUCTION ROUTES — GREY / BLUE / GREEN
Unabated fossil reforming — the full upstream and process carbon burden.
Fossil reforming with capture — residual emission plus the energy used to capture.
Renewable electrolysis — near-zero where the origin grid behind it is genuinely clean.
* Green turns on the origin-grid intensity behind the electrolyser. The declared figure follows the production route — only an evidenced actual lets a blue or green producer claim the lower embedded emissions they have achieved.
THE EMISSION IS THE PRODUCTION ROUTE — CN 2804 10 00
Hydrogen enters CBAM under a single heading, but the declared figure turns on the production route and, for electrolysis, the origin-grid intensity. Where the route is unevidenced, the declaration falls back to a conservative default — so a blue or green producer needs the evidence chain in place before the 30 September 2027 deadline, not after. Published route and grid data layer into the CBAM hydrogen data hub as it is confirmed — this page does not restate figures that are not yet final.
WHAT THE XML MUST CONTAIN
INSTALLATION DATA
- Country of origin
- Production route (grey / blue / green)
- Capture installation where CCS applies
- Electricity source for electrolysis
- Reporting period
GOODS DATA
- CN code 2804 10 00
- Net quantity (tonnes)
- Product designation — hydrogen
- Unit of measure
- Production installation reference
EMISSIONS DATA
- Declared production route
- Origin-grid emission factor where electrolysis applies
- Default versus actual basis
- Embedded emissions (tCO₂)
- Evidence reference for actual claims
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.
How are CBAM emissions for hydrogen calculated — is there a single process default like cement?
No. Hydrogen has no single process-emission default in the way cement clinker does. Its embedded carbon is driven by the production route and, for electrolytic hydrogen, by the carbon intensity of the origin-country grid behind the electrolyser. Grey hydrogen from unabated fossil reforming sits at the high end of the spread; blue hydrogen with carbon capture and storage is materially lower; green hydrogen from renewable electrolysis approaches near-zero. The same tonne of hydrogen therefore carries very different embedded emissions depending on how, and where, it was produced.
Why does verified actual data matter more for hydrogen than for other sectors?
Because the spread between routes is so wide. A default basis cannot distinguish grey from green, so it defaults conservatively — and for a low-carbon producer that overstates the liability. Declaring a verified actual figure, supported by route evidence and, for electrolysis, the origin-grid factor, is what lets a blue or green producer claim the lower embedded emissions they have actually achieved. Carbon Mandate prepares the declaration on that evidenced basis; your EU importer files it.
My EU importer is asking for an XML — what does Carbon Mandate actually produce?
Carbon Mandate prepares the CBAM XML on your declared production route and validates it against the live DG TAXUD XSD schema before transmission. A PDF report or spreadsheet is not an accepted submission format. We are the preparer, not the filer: your EU importer submits the file to the EU Registry as the authorised CBAM declarant, and we are never the verifier. You receive a registry-ready file, not a communication template.
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