Does CBAM apply to my product if my customer ships through a non-EU port?

CBAM applies on EU customs entry. The shipping route does not change scope. CN 2523 covers Portland cement, aluminous cement, and related products; verify your specific code against Annex I of Regulation (EU) 2023/956.

What CN codes are covered for cement under CBAM?

CBAM covers goods under Chapter 2523 of the EU Combined Nomenclature, including Portland cement (2523.21 white, 2523.29 grey), aluminous cement (2523.30), slag cement (2523.90), and similar hydraulic cements. Calcined clays and certain materials under 2521 may also be in scope. Verify your exact CN code against Annex I of Regulation (EU) 2023/956.

How does CBAM calculate emissions if I do not submit verified data?

Under Regulation (EU) 2025/2621, importers without verified actual emissions data must use country × product default values published by the European Commission. Default values include a statutory markup: 10% in 2026, 20% in 2027, and 30% from 2028 onwards. Submitting verified actual data from your installation, verified by an accredited verifier, almost always produces a lower CBAM liability than the default.

When is the first CBAM declaration due for cement?

The first annual CBAM declaration is due 30 September 2027, covering imports made during calendar year 2026. Quarterly transitional reports continued through Q4 2025. From 1 January 2026, only the EU importer filing with the EU Registry may import covered cement goods.

Why do process emissions matter for cement?

Around 60% of clinker emissions come from limestone calcination — a chemical process where CaCO₃ decomposes into CaO and CO₂. This is distinct from fuel combustion emissions (around 40%). Annex IV of the CBAM Regulation requires separate declaration of process and combustion emissions, and verifiers check both independently.

How is the clinker-to-cement ratio used in CBAM declarations?

The clinker-to-cement ratio (clinker factor) determines how much CBAM-scope material is in each tonne of finished cement. Portland CEM I cement is around 95% clinker; blended cements like CEM II/B or CEM III/A can be 35-65% clinker. Lower clinker factors produce lower embedded emissions and lower CBAM liability.

Are supplementary cementitious materials (SCMs) treated as zero-emission?

Ground granulated blast furnace slag (GGBFS) and fly ash, when used as SCMs in blended cement, carry only their processing energy as embedded emissions — typically 10-50 kg CO₂e/t versus 800+ kg CO₂e/t for clinker. Producers must document SCM origin and the blended-cement clinker factor per Annex IV.

What happens if my CBAM XML fails verification?

The EU importer filing with the EU Registry will reject the XML and request corrections. Common rejection reasons include CN code mismatches, missing clinker factor declaration, missing process vs combustion emissions split, default values exceeding the 20% threshold imposed from July 2024, and missing Annex IV calculation method declarations. Carbon Mandate's free XML scan checks file structure against CBAM schema requirements for cement before transmission.

CN 2523 · CN 2521 · CEMENT

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Default-value markup scheduleArt. 5(3) Reg (EU) 2025/2621

2026 default markupCurrent+10%above verified default

2027 default markup+20%above verified default

2028 default markup+30%above verified default

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Cement

In scope

Clinker and cement products under Annex I. Default benchmark applies until verified actuals.

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Emission data · Validation

The published Annex I defaults for this sector, and the rules every XML is checked against before release.

Annex I default emission values

Country	Route	tCO₂e/t	CN
India	PORTLAND	1.48	2523 29 00
China	PORTLAND	1.42	2523 29 00
South Korea	PORTLAND	0.94	2523 29 00
Ukraine	PORTLAND	1.38	2523 29 00
Egypt	PORTLAND	1.29	2523 29 00
Other	PORTLAND	1.44	2523 29 00

PORTLAND route shown. Clinker and blended cement routes also published in Annex I.

Source: Reg (EU) 2025/2621 Annex I · PDF-verified · carbonmandate.com

Validation rules applied to this sector

CE-01Declared CN code falls outside chapter 2523 (cement) — verifier will reject.error

CE-02Root reportingPeriod element missing — required for every declaration.error

CE-03Producer EORI does not match member-state format pattern.warning

CE-04Total embedded emissions cannot be zero for declared production volume.error

CE-05calculationMethodId missing — Annex IV requires explicit declaration of method used.error

CE-06clinkerRatio missing — Annex IV requires clinker-to-cement ratio for cement.warning

25 rules total · full rule set applied on every scan

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Regulatory calendar

The dates that move the liability.

Every deadline below is fixed by Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Plan verifier bookings, ACD applications, and supplier data collection against the regulatory calendar below — not the financial year.

1 Jan 2026Definitive period started—
31 Mar 2026Late ACD application deadline—
1 Feb 2027CBAM certificate purchasing opens—
30 Sep 2027First annual CBAM declaration due—

Source: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083

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