CBAM has moved from a reporting exercise to a cost, and the burden of it lands upstream. If you supply steel, aluminium, cement, or fertiliser into the EU, your customers now need embedded emissions data from you at a granularity most metals producers do not currently hold.
What the declaration actually needs
Not an annual corporate average. Embedded emissions per tonne of the specific goods shipped, split into direct and indirect, attributed to the production route those goods actually took. A plant running both EAF and BF-BOF routes cannot answer with one number.
Why annual averages fail
- The reporting period is quarterly, and an annual average cannot be disaggregated backwards into it.
- Emissions intensity varies materially with scrap ratio, energy mix, and utilisation, none of which are constant across a year.
- Verification requires the calculation to be reproducible from underlying data, which an average is not.
The data you need to be holding
- Energy consumption metered by production route, not by site.
- Production tonnage time-aligned with that consumption.
- Input material composition, particularly scrap ratio, per heat or per campaign.
- Purchased electricity with its supplier emissions factor for the actual period.
- A lineage trail from each declared figure back to the readings behind it.
The commercial dimension
Buyers will increasingly prefer suppliers who can produce verified primary data over those who cannot, because the alternative is default values that price the carbon conservatively — against the buyer. Being able to evidence a lower actual intensity is becoming a commercial advantage, not just a compliance obligation.
Written from deployment experience across multiple sites. Patterns are described without identifying any customer — we are under confidentiality with the operators involved.
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