Objection pursuant to Rule 115(2) and (3) of the Rules of Procedure on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goods

Please refer to the attached letter, which offers our comments on the proposed EU Carbon Border Adjustment Mechanism (CBAM) rules on the methodology for calculating emissions embedded in CBAM goods. Please do not hesitate to contact us if you have questions or seek any clarification on this letter. We remain at your service.

For the determination of the embedded emissions, Solvays position is that the scope should be limited to direct emissions, including the emissions linked to the heat generation.The calculation of carbon footprint of imported CBAM products shall encompass all the activities of the value chain (from cradle to European border) and all the greenhouse gas emissions associated to those activities.

The UK and EU share comparable climate neutrality commitments, including legally binding net-zero targets by 2050. Both the UK and EU have Emissions Trading Systems (ETS) that are broadly aligned, and a political agreement reached on 19 May 2025 showing strong commitment linking these schemes. However, the current CBAM framework does not account for this convergence.

Aluminium France is concerned about the risks of circumvention linked to the current design of CBAM. Therefore, with regard to direct emissions, we call for a single default value based on the average carbon content of the melting country.

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Técnicas Reunidas (hereinafter TR) is a global leader in engineering and construction, specialising in the design and execution of complex industrial facilities. Headquartered in Madrid, which serves as its Operational Excellence Centre, the company operates engineering hubs in Spain, India, Turkey, Saudi Arabia, Chile, and the United Arab Emirates, employing more than 12,000 professionals.

(i) The current CBAM emission calculation using primary data is overly complex and burdensome. Supplier data acquisition remains a major hurdle, as data (e.g. on installations, processes, emissions location) is often unavailable or difficult to obtain. Many suppliers may be unable or unwilling to provide this kind of information.

The Government of Lesotho recognises the importance of robust methodologies for calculating embedded emissions under CBAM. However, we wish the following considerations can be taken into account: i) Lesotho, like many Least Developed Countries (LDCs) face significant capacity constraints in establishing advanced Measuring, Reporting, and Verification (MRV) systems.

We support the overall objective of CBAM as a tool to put a fair price on the carbon emitted during the production of carbon-intensive goods imported into the EU, to avoid carbon leakage, and to encourage cleaner industrial production in non-EU countries.

Our recommendations: - For steel and aluminium, Address scrap-related circumvention by either: o Attributing emissions to both pre- and post-consumer scrap, or o Using systematic default values - For cement, Apply systematic default values, to prevent resource reallocation without real emissions reductions - Improve indirect emissions accounting Either replace plant-level electricity emissions reporting with a…

Megasa appreciates the opportunity to provide its comments on the CBAM methodology. As a producer of steel through scrap based electric arc furnaces (EAF), we are committed to the EUs decarbonisation objectives and to a competitive, sustainable steel industry.

Businesses whether small or large, require clear and simple rules to allow for setting up efficient processes dealing with CBAM requirements in general, assess impacts accurately, conduct proper financial planning and reduce any type of risk to a minimum. With missing default and benchmark values, unclear verification procedures and liability rules for supplier emissions data none of the above is possible.

This document presents the comments of the Brazilian Aluminium Association (ABAL) on the European Commissions Public Consultation for Preparing an Implementing Regulation on the emissions calculation methodology for the definitive phase for products under the scope of the Carbon Border Adjustment Measure.

This comment recommends using biogenic content testing (Carbon-14) to determine the biogenic carbon content of CO2 emissions embedded into CBAM products and to calculate emissions savings under the CBAM framework.

Duferco International Trading Holding S.A. (DITH) thanks the European Commission for the opportunity to participate in this public consultation on the implementation of CBAM and provides its full comment in the attached file.

As a steel producer located outside the European Union, with clients who purchase steel from the European bloc, we would like to share some considerations regarding the methodology presented in the documents Guidance on CBAM Implementation for Installation Operators Outside the EU and Guidance on CBAM Implementation for Importers of Goods into the EU, particularly with respect to the calculation of emission…

DiXi Group NGO welcomes the opportunity to contribute to the European Commissions (EC) call for evidence on the implementation of the Carbon Border Adjustment Mechanism (CBAM), in particular, on the rules on the methodology for calculating emissions embedded in CBAM goods for the definitive period starting on January 1, 2026. Details are provided in the attached file.

The Spanish Aluminium Association strongly request a detailed analysis of the implications of CBAM and its implementation for the European aluminium industry, taking into consideration the declaration of aluminium as a critical raw material for the EU, the Steel and Metals Action Plan, and the dependance of primary aluminium imports to maintain the industrial capacity of the European aluminium sector,

For the determination of embedded emissions, the scope should remain only on direct emissions, including those linked to heat generation. We recommend not extending CBAM scope to indirect emissions for industries that are already covered by the EU ETS Indirect Carbon Cost Compensation Scheme and to avoid competition distortion within the European Union adapt the indirect carbon cost compensation scheme to ensure…

Brazil Steel Institute is a non-profit association that congregates and represents the Brazilian steelmaking companies. We understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities…

The Würth Group welcomes and commented on the initiative of the European Commission to define the methodology for the final CBAM period as of 1 January 2026. After two years of implementing CBAM regulation, a key challenge remains the availability and quality of data along global supply chains.

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The methodology should put measured, site-specific actual data first, with clear, simple quality checks so numbers are reliable. When measured data is not available, it should allow practical fallback values that are published, explain their uncertainty, and do not unfairly punish low-carbon producers.

Over the years, Türkiye and EU has very special relations including Customs Union and Free Trade Agreement and Türkiye is treated just like a member country in trade issues. CBAM is clearly abolish these free trade conditions between the parties.

CBAM Methodology (definitive period from 2026) UNESID values the opportunity to comment on the CBAM methodology. We believe several elements require clarification or reinforcement: 1. Melted and poured + mechanical transformation. CBAM must require proof of the plant where the steel was melted and poured, complemented with information on subsequent thermo-mechanical transformation (rolling, coating, etc.).

For the determination of the embedded emissions, the scope should remain only on direct emissions, including those linked to the heat generation.We recommend not extending CBAM scope to indirect emissions for industries that are already covered by the EU ETS Indirect Carbon Cost Compensation Scheme. Due to the marginal pricing system of power in Europe, power prices are affected by the price of CO2 allowances.

Comments ON ALUMÍNIO International Aluminium Institute (IAI) SETOR The IAI aims to promote the sustainable development of the global aluminium industry and works closely with national and regional associations, including ABAL.

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Baker Hughes is a leading energy technology company that provides solutions for energy and industrial customers worldwide. We design, manufacture, and service transformative technologies to help take energy forward making it safer, cleaner, and more efficient for the people and the planet. While we operate globally, Europe is a key market and corporate home for Baker Hughes.

Over the past three years, my company has been preparing compliance measures for secondary iron and steel products subject to the EU-CBAM. Based on this experience, I would like to respectfully submit the following observations and requests regarding the definitive period. First, we request that the Council promptly adopt the omnibus bill already approved by the European Parliament.

EDF group welcomes the opportunity to share its feedback on CBAM implementing act regarding emission accounting methodologies. EDF group's main concern relates to how electricity is treated under the current framework. Due to its unique characteristics, an effective implementation of the Carbon Border Adjustment Mechanism (CBAM) for the electricity sector poses challenges.

Response to the European Commission Call for Evidence on the methodology for the definitive period starting on 1 January 2026. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

The EU achieved a remarkable 13% reduction in electricity-related CO emissions, reaching its lowest level on record in 2024. Furthermore, Europe continues to lead efforts to decarbonize its power sector. This progress is driven by a strong shift toward clean energy, with renewables and nuclear accounting for over 70% of electricity generation.

Nemo Link Limited operates the 1000MW HVDC electricity interconnector between GB and Belgium. Please find attached the joint response from Nemo Link and other EU and GB Transmission System Operators including RTE, Elia, Energinet, National Grid Interconnectors, BritNed, ElecLink, GreenLink.

We welcome the opportunity to provide our views to the consultation on the Carbon Border Adjustment Mechanism (CBAM) methodology for the definitive period starting on 1 January 2026. The current EU CBAM legislation will lead to many unintended and negative consequences for electricity trade, notably between the EU and the UK.

Thank you for the opportunity to provide feedback on the methodology for calculating default emission factors under the definitive regime of the Carbon Border Adjustment Mechanism (CBAM), as well as the evidentiary requirements for using actual emissions and the conditions for applying alternative default values.

We at SolarPower Europe, the EU-level solar industry association representing close to 320 members across the solar value chain, note that although solar is not currently targeted under CBAM, the Commission has signalled a likely expansion to other downstream sectors.

MPE represents the European producers of rigid metal packaging, a sector that relies heavily on competitively priced steel and aluminium. We share the EUs climate neutrality objectives and recognise the Carbon Border Adjustment Mechanism (CBAM) as a key tool to reduce carbon leakage.

We welcome the opportunity to provide feedback on the different calls for evidence on the Carbon Border Adjustment Mechanism (CBAM). We strongly support a timely, effective and full implementation of the EU CBAM in 2026. In a challenging international context, regulatory stability and predictability are quintessential for a competitive and clean European industrial basis.

The call for evidence organised here by the Commission addresses crucial topics in the implementation of the CBAM and the consideration of its impacts. The difficulties faced by the three implementing acts are further increased for those sectors that have requested to be covered by the CBAM. This is why FIEEC calls for the suspension of the scheme until structural obstacles are removed.

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DEAR Sirs, Please see attached the joint position by the Lithuanian Confederation of Industrialists, Lithuanian Business Confederation and Association Investor’s Forum. Heres a short summary of the Lithuanian industry associations position on CBAM: Support in principle: They welcome CBAM as a tool to prevent carbon leakage and support EU climate goals.

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RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 7 of the CBAM Regulation. Clear rules on the calculation of embedded emissions are essential to safeguard competitiveness and maintain the credibility of CBAM.

Carbon border adjustment mechanism (CBAM) methodology for the definitive period starting on 1 January 2026 1. Direct embedded emissions based For the cement sector the Monitoring and Reporting Regulation for the EU ETS and its implementation documents must be the basis for the determination of these emissions.

Due to the character limit, we are unable to provide our full response in this box. Please refer to the attached full response. Interconnection on the Ireland-United Kingdom border o Electricity is a unique commodity in CBAMs scope, traded within an interconnected network where flows cannot be physically traced.

As an Organization operating within global supply chains, We are facing multifaceted challenges in complying with the Carbon Border Adjustment Mechanism (CBAM). A major concern is the difficulty in tracing actual embedded emissions from non-EU suppliers, many of whom lack awareness or infrastructure to provide verified, installation level data aligned with EU Monitoring and Reporting Regulation (MRR) standards.

1. as far as I know, I heard that in some products like steel, the indirect embedded emissions maybe excluded. In the sense to avoid the the leakage of carbon. I recommend that direct and indirect remain the top priority. 2. for the determination of embedded emissions for electricity. the default is a good start. However, the national database should replace the default emission with more accuracy and reliability.

As importers of goods subject to the Carbon Border Adjustment Mechanism (CBAM), such as clinker, we are facing an imminent loss of competitiveness. . The regulatory framework is unclear and therefore the market with this uncertainty is not ready for its imminent implementation on 1 January 2026.

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Eren Holding is a company with long-standing trade relations with the European Union and a regular exporter to the EU market, in particular in the cement sector. The Carbon Border Adjustment Mechanism (CBAM), adopted under the European Green Deal, has direct implications for our operations and trade with the EU.

The Ministry of Agriculture and Environment of the Government of Mozambique respectfully submits this comment urging the European Commission to include Scope 2 emissions from electricity use in all sectors in the EU Carbon Border Adjustment Mechanism (CBAM) when the definitive phase begins in 2026.

Orgalim welcomes the opportunity to respond to the call for evidence on the CBAM methodology for the definitive period starting on 1 January 2026. Our response can be found in the attached document which is our input regarding the necessary simplification measures for CBAM.

Lithuanian Business Confederation (LVK) submits its position to the ongoing European Commission consultations on the Carbon Border Adjustment Mechanism (CBAM). The document outlines key challenges for businesses, emphasizes the need for proportional and carefully assessed implementation, and proposes measures to safeguard EU industry competitiveness while supporting decarbonisation efforts.

Dear Sir or Madam, Thank you for the opportunity to provide feedback on the calculation methodology for default emission factors under the definitive CBAM regime, the evidence required to claim actual emissions, and the conditions for using alternative default values. We have submitted our opinion and suggestions as attached document to this message.

Emissions trading, as a market-based solution, is the most efficient way to achieve climate change objectives. In order to establish a level plating field with suppliers from other countries, carbon border adjustment is essential until all relevant competitors have established similar rules.

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Nvalue AG is a climate consultancy specialized in emissions reporting, renewable energy solutions, and environmental markets. We support companies and institutions worldwide in meeting their climate goals through robust emissions accounting and renewable energy procurement. In its current form, the CBAM could inadvertently hinder rather than support the growth of renewable energy in non-European countries.

Please find enclosed some comments submitted on behalf of NV Bekaert S.A. to the call for evidence on the CBAM implementation: rules on the methodology for calculating emissions embedded in CBAM goods; rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation; rules on the deduction of the carbon price paid in a third country

CMC Poland , supporting the Polish Steel Association and EUROFERs position, welcomes the EUs efforts to implement CBAM as a tool to reduce carbon leakage and ensure fair competition. For the mechanism to be effective, several adjustments are needed: During the transitional phase (e.g.

To whom it may concern, NESO is submitting evidence on the nature of the current methodology and its determination of embedded emissions for electricity. Please see the portion of our submission in regard to emission intensity that was part of the previous submission in response to the Call for Evidence on Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity…

Rio Tinto has maintained an important presence in Europe for more than 150 years. We have put the low-carbon transition at the heart of our business strategy: combining investments in commodities that enable the energy transition with actions to decarbonise our operations and value chains.

Recommending Recognition of China's Green Power Trading in CBAM Indirect Carbon Emissions Accounting Abstract: China has established its green power trading mechanism, which has become the primary measurement for greening electricity consumption across diverse power consumers.

With the full implementation of the CBAM scheduled for 1 January 2026, major concerns remain unresolved. The regulatory framework is unfinished, operational procedures are undefined, and importers still lack the essential information needed to comply.

On behalf of the steelmaking industry, I respectfully submit the following request to the CBAM Committee. We strongly encourage the Committee to uphold the current rules and regulations that allow suppliers the discretion to separate and report emission data according to different production groups.

BMW welcomes the opportunity to contribute to the ongoing EU consultations regarding the CBAM: methodology for the definitive period; carbon price paid in a third country; adjustment of obligation to surrender them to take account of free ETS allowances.

In the context of the European Commission’s stakeholder consultation on the Carbon Border Adjustment Mechanism (CBAM) methodology for the final period starting on 1 January 2026, the VCI would like to comment as follows: (1) In order to reduce the red tape for the CBAM declaration, it should be clarified that empty refill containers (e.g.

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1. Recognition of Türkiye's Unlicensed Self-Consumption Renewables We urge the Commission to recognise Türkiye's unlicensed self-consumption renewable generation (onsite/offsite PV) as 0 tCO/MWh actual emissions in CBAM (Articles 7, 9). This regime has a clear legal basis, strict metering, SCADA oversight, and operator-issued monthly balancing statements ensuring no double counting and full MRV integrity.

Bellona Europa has long supported the efforts to establish a Carbon Border Adjustment Mechanism (CBAM) as a way to strengthen the EUs carbon price signal while protecting European producers from the risk of carbon leakage caused by uneven climate ambition worldwide.

The current methodology for calculating embedded carbon under the EU Emissions Trading System (ETS) and the Carbon Border Adjustment Mechanism (CBAM) does not adequately recognise the environmental benefits of waste-derived fuels compared to fossil fuels.

Topsoe welcomes the opportunity to provide feedback on the CBAM methodology for the definitive period starting in 2026. The EU has identified renewable hydrogen as a key pathway for reducing greenhouse gas emissions, setting ambitious targets for the uptake of renewable fuels of non-biological origin under the revised Renewable Energy Directive and the ReFuelEU Aviation Regulation.

See below Eurometaux's key messages, and attached our detailed position on the CBAM methodology. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals. Key points: 1.

A central principle of CBAM must be to establish a strong incentive for importers to report their verified real embedded CO2 emissions by defining highly conservative default values. If standard values are set low or average, importers of highly emission intensive products will simply rely on these defaults rather than disclosing verified data.

As the first ultra-clean steelmaking facility in Spain, Hydnum Steel strongly supports the CBAM and welcomes the European Commissions efforts to drive global decarbonization in steel and other essential sectors. Please find attached our contribution to the public consultation on the CBAM. We hope it supports the ongoing work, and we remain available for any further clarification or dialogue.

UNFAIR POSITION OF EU IMPORTERS IN RESPECT OF THE USE OF ACTUAL EMISSION VALUES EU importers have many different sources of supply of CBAM goods from third countries. The number of installations in third countries that should be verified by accredited CBAM verifiers is very large.

CBAM design is not suitable to be extended to the complex value chains such as those of organic chemicals and polymers. Four key conditions a solution for exports, full value chain coverage, consideration of indirect carbon costs, and practical feasibilityremain unmet.

The FachverbandToolindustrie e.V. (FWI) welcomes the opportunity to comment on the CBAM methodology in this Call for Evidence. The AMI is the association of tool manufacturers in Germany and is therefore the central representative body for companies in the sector. We support the Carbon Border Adjustment Mechanism (CBAM) as a means to avoid carbon leakage and ensure fair competition.

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1. If the majority of the emissions of an imported product originate from non-EU producers precursors (with different origins), establishing country-specific default values would be misleading. Default values should therefore be determined with this consideration in mind. 2. Limiting verification exclusively to EU-accredited firms or verifiers will create a bottleneck.

Thank you for your consultation on these CBAM topics. With the "Commission proposal to simplify and strengthen the CBAM", the Commission wants to simplify the CBAM and align it with the EU ETS. Bringing the actual regulation to an operationally stable state should be achieved before December 2025 to avoid any issues for the millions of manufacturing companies using and disrupting the EU supply chains.

We urge the European Commission to hold further public consultations on the draft implementing rules concerning the methodology for calculating emissions embedded in CBAM goods, the adjustment of CBAM certificates to reflect the EU ETS free allowances, and the rules on the deduction of the carbon price paid in a third country. This is essential to ensure transparency and uphold the rights of all stakeholders.

Align the CBAM methodology with already globally recognised schemes (e.g. GHG Protocol, ISO 14064, MRV UNFCCC). This avoids double reporting, facilitates the participation of global companies and improves the comparability of data.

Filed in Italian · English published by the European Commission

The EU-approach to calculate CO2-content for CBAM-relevant goods appears to be a theoretical approach than an feasible way to handle the data. Looking into CO2 footprint calculations it is nearly impossible to perform a calulation on CO2-content for a product in terms of exact determination.

Article 7(7) requires embedded emissions to be calculated according to harmonised rules; Article 9(4) demands that benchmarks used for adjustments mirror ETS; Article 10(2) ensures uniformity of conditions. These provisions form a legal obligation: CBAM cannot diverge from ETS logic. Actual values and defaults ESPA strongly supports that actual values, verified under ETS-consistent MRV systems, remain the rule.

— The calculation of embedded emissions must be made in accordance with the ETS regulations, it must include all CO2 emissions associated with the manufacture of the product (steel), such as the combustion of natural gas and other fossil fuels. — The CO2 emissions for electricity must be determined with the off-take factor specific to the country of production (i.e.

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PSE position on the impact of CBAM on cross-border electricity flows and trade: Polish TSO supports CBAMs climate and competitiveness goals while stressing that implementation must not weaken security, reliability, or market integration. In this light we propose: 1. Exclusion of TSOs from obligations arising from CBAM.

Dear Sir/Madam, As a cold rolling mill based in Türkiye and exporting to the European Union, we welcome the opportunity to provide feedback on the implementation of the Carbon Border Adjustment Mechanism (CBAM). While we fully support the EUs climate objectives, it is essential that CBAM reflects actual industrial practices and ensures fair competition. Our key considerations are attached.

With reference to the suggestion already made on 24/09/2025 by SMA Serbatoi Spa, which we attach again We request that a rule be introduced whereby, among the precursor materials for calculating the carbon emissions of non-European companies, materials exported from Europe for sale or on a processing contract basis to the non-European company itself and used for the production of products subsequently exported to…

Emirates Global Aluminium (EGA) welcomes the opportunity to contribute to the European Commissions Call for Evidence on CBAM. As a material supplier of primary aluminium to the EU, EGA supports CBAMs goal of ensuring a level playing field between EU and non-EU producers in respect to the costing of emissions and aligning trade policy with climate objectives. Please see attached our comments.

We welcome the Commission’s efforts to standardise and communicate in a transparent manner the determination of direct and indirect embedded emissions and the use of default values. Otherwise, different interpretations and measurement approaches lead to biases and a lack of comparability of data.

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UFE supports the principle underlying the Carbon Border Adjustment Mechanism (CBAM), which aims to preserve the competitiveness of European industry and prevent carbon leakage, in a context of increased climate ambition at European level. In this mechanism, the emission factor represents the carbon content in the price of electricity.

We welcome the European Unions efforts to ensure a level playing field for climate ambition and offer the following recommendations to strengthen CBAMs effectiveness, transparency, and implementability. 1) Standardization of Carbon Accounting The EU should publish sector-specific guidance for embedded-emissions calculation, including detailed system boundaries, allocation rules, data quality hierarchies, and…

BlueScope is an Australian headquartered producer and exporter of iron and steel products and welcomes the opportunity to provide feedback on the Carbon Border Adjustment Mechanism (CBAM) methodology for the definitive period commencing 1 January 2026.

This submission presents the comments of the Hyundai Steel Company, established in the Republic of Korea (South Korea), Hyundai Steel Slovakia s.r.o. and Hyundai Steel Czech Republic s.r.o., (collectively referred to as the Hyundai Steel Group or "HSG"). HSG recognizes the challenges in setting all the rules needed to properly enforce the CBAM.

1. Rules on the Methodology for Calculating Emissions Embodied in Goods under the Carbon Border Adjustment Mechanism (CBAM) 1.1 Calculation of Directly Embodied Emissions Recommendation: Draft experience summary reports should be released regularly (e.g., semi-annually) to keep stakeholders informed of the revision direction.

For the use of actual emissions data, the definitive CBAM methodology should provide a detailed explanation of how verification will operate. In particular, it must set out the local-based conditions under which verified data can be accepted, ensuring clarity on how verification requirements are applied at the installation and operator level in each jurisdiction.

Keidanren (Japan Business Federation) is a comprehensive economic organization with a membership comprised of 1,574 member companies in Japan, 106 nationwide industrial associations, and 47 regional economic organizations.

We would like to strongly reaffirm our support for the environmental objectives of the CBAM. At the same time, we consider it important to underline that the implementation of the mechanism poses certain structural challenges for companies operating with multi-plant, process-based, and project-oriented production models.

Our feedback was classified into the following aspects; namely, default values for emissions, challenges regarding the precursor emissions, reporting on the mix of grid and on-site electricity, and the employment of national electricity grid emission factors. Due to the lengthy content, we opted to provide it in the attached document.

Since 2021, China has initiated green power trading, a mechanism that bundles the electricity output and green attributes (green certificates) of unsubsidized wind and solar projects for transaction. These trades can be conducted on a multi-year, annual, or monthly basis and are largely aligned with the PPA (Power Purchase Agreement) mechanisms used in Europe. Key features of the mechanism include: 1.

These comments are particular to the European Commissions request related to the methodology for assessing default values and determining embedded emissions. They reflect deep analysis of CBAM-style policy, consultations with industry, and a literature review of best practices for the assessment of emissions intensity.

Im part of the European Space Agency and have expertise in the development of Earth Observation-based applications, especially in the field of greenhouse gases and air quality monitoring. We recommend taking into consideration the inclusion of satellite remote sensing technologies as a potential data source for Monitoring, Reporting, Verification, for the prevention of circumvention and/or for enforcement purposes…

Siemens AG welcomes this opportunity to provide feedback on the implementation of CBAM. Please find below and attached our main recommendations: Standardise emissions methodology and simplify reporting with user-friendly systems and minimal verification requirements. Define clear, grid-specific emission factors for electricity to incentivize low-carbon energy use in production.

Europacable welcomes the opportunity to respond to the call for evidence on the CBAM methodology for the definitive period starting on 1 January 2026. A study commissioned by Europacable in 2023 confirmed that aluminium power cables are a key technology to empower Europes decarbonisation.

CLEPA, the European Association of Automotive Suppliers, supports CBAM as a tool to prevent carbon leakage and ensure fair competition. However, as the definitive period approaches businesses urgently require operational clarity. Timing The immediate priority is the swift publication of default values, benchmark values, and verification rules.

As a European manufacturing company primarily engaged in the production and export of mining machinery and components to markets outside the European Union, we respectfully submit the following concern regarding the current scope of the Carbon Border Adjustment Mechanism (CBAM). Many of the goods we export may include components originally imported into the EU and covered under CBAM.

Confapi, representing Italian private industrial SMEs, acknowledges the importance of the CBAM in preventing carbon leakage but considers its current design disproportionate and burdensome for Industrial SMEs. The calculation methodology must ensure environmental integrity, legal certainty and proportionality of obligations, avoiding duplication with existing rules under Regulation (EU) 2023/956, the EU ETS…

On behalf of VDMA, we welcome the opportunity to contribute to the public consultation on the implementing act concerning the methodology for determining embedded emissions required for CBAM reporting. We strongly urge the swift adoption of this act by Q3 2025, alongside the remaining implementing legislation, as a matter of urgency. Please find our feedback in the attached document.

Method for the calculation of embedded emissions (Rules for determining greenhouse gas emissions in imported goods pursuant to Article 7 and Annex II of Regulation (EU) 2023/956) For complex goods listed in Annex II, Viet Nam requests that the EU, at the earliest possible stage, publish a detailed set of default values and default carbon prices by country and by sector.

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start in 2026.

(1)Clear benchmark figures for each final product (especially Urea) listed in the CBAM product list needs to be set, with specific figures and defined methods for calculating whether for the final product or the local emission. (2)The transition period after the official announcement of benchmark figures should be at least five years.

With reference to the entry into force of the Carbon Border Adjustment Mechanism (CBAM), scheduled for January 2026, our company would like to submit a few observations regarding the implementation of the regulation and its practical impact on the industrial fabric, particularly for SMEs operating in the import of raw materials and semi-finished products from non-EU countries. 1.

As a steel producer outside the EU, we understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities involving the iron and steel production sector, especially for integrated plants on…

As a steel producer outside the EU, we understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities involving the iron and steel production sector, especially for integrated plants on…

WE Soda urges the EU Commission to expand the Carbon Border Adjustment Mechanism (CBAM) to include the soda ash and glass industries in line with the EU policy objectives. We call for an integrated assessment and design of CBAM benchmarks to ensure low-carbon soda ash is treated fairly.

While reaffirming Fincantieris well-known position of support for decarbonization objectives, but also concern regarding the implementation mechanisms of the CBAM that could negatively affect the specific shipbuilding sector for which we request an exemption due to its strategic importance and particular characteristics (see analysis, rationale, and proposals in the attached note) we are certainly in favor of any…

o To accurately represent the emissions currently captured in EU ETS, only direct emissions from aluminum should be considered. o Is it crucial to allow the unconditional use of default values to minimize administrative burdens and prevent disruptions to European businesses.

1.Include Emissions from Purchased Thermal Energy in the Scope of Indirect Emission Accounting It is recommended that carbon emissions from purchased thermal energy be included in the scope of indirect emission accounting. This aligns with existing international practices and helps enterprises manage carbon emissions more efficiently while complying with other carbon emission management rules.

The methodology for national monitoring under CBAM must be fair, practical, and differentiated. While accuracy in calculating direct embedded emissions is important, mandatory precision monitoring imposes unsustainable burdens on SMEs. A tiered approach should be adopted: large enterprises using precise monitoring, SMEs using EU-approved default values with a transition period.

Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the opportunity to respond to the CBAM Call for Evidence and welcome the EUs efforts to address carbon leakage.

Die STAHLWILLE Eduard Wille GmbH unterstützt CBAM grundsätzlich. In seiner derzeitigen Ausgestaltung weist CBAM jedoch eine entscheidende Lücke auf: Nachgelagerte Metallprodukte sind nicht erfasst. Dies führt zu einem erheblichen Wettbewerbsungleichgewicht zwischen Herstellern innerhalb und außerhalb der EU.

APPLiA welcomes the opportunity to provide feedback on the methodology for the definitive period of the CBAM, starting 1 January 2026. While the methodology for products currently in scope is the primary focus of this consultation, it is equally important to prepare the framework for the future extension to downstream goods.

The European Tool Association (CEO) welcomes the opportunity to contribute to the call for evidence on the CBAM methodology. While we support CBAM as a tool to prevent carbon leakage and ensure fair competition, it leaves a critical gap in its current scope. CEO strongly calls on the European Commission to include downstream products under CBAM.

FEAD, representing the European private waste and resource management industry, supports an ambitious CBAM as a crucial tool to reinforce the competitiveness of EU industry, and contribute to achieving the Unions climate and circular economy objectives. Recycling in the EU, in particular plastics recycling, is currently under significant economic pressure.

Siemens Healthineers appreciates the European Commissions ongoing efforts towards simplification of the CBAM, which should be maintained and further strengthened. We particularly welcome the introduction of the 50t de minimis threshold and the use of default values for emissions calculation, both of which are essential in reducing unnecessary administrative burdens for companies and ensuring proportionality.

We have many doubts about the methodology for calculating embedded emissions. First, the verifiability of the data received is based on declarations from non-EU suppliers, which are currently not verifiable by the importer. The methods used to measure these emissions might differ from those required by the EU, and are sometimes incomplete.

Filed in Italian · English published by the European Commission

EUROMETAL supports CBAM as a cornerstone of EU climate and trade policy. Its success depends on the clarity and stability of rules, the adoption of workable methodologies adapted to SMEs in steel distribution, fair recognition of carbon prices paid abroad, proportionate and harmonised reporting obligations, and closing the loophole by extending CBAM coverage to steel derivatives.

We, the Japan Iron and Steel federation, propose the following for the effective implementation of CBAM: (1) adopt the bubble approach, as applied during Phase 1, to reduce excessive administrative and compliance burdens; (2) if default values must be used, allow governments which maintain mutual trust relationships with the EU (e.g., through EPAs), with statutory reporting systems to provide reliable national…

Attached is the Ministry of Economic Affairs, Republic of China (Taiwan), paper outlining our comments and recommendations on this consultation. 1.Public Consultation and Methodology: Upon publishing draft embedded emissions methods, the EU should run a public consultation that (i) clearly defines required data and technical standards (boundaries, sources, verification/assurance) to avoid divergent interpretations…

Subject: Commentary on the European Commission's Call for Evidence for the Carbon Border Adjustment Mechanism (CBAM) I. Implementing Act (IA) Rules on the methodology for calculating emissions embedded in CBAM goods The implementing rules must take into account the specific circumstances of developing countries such as Egypt, which are still in the early stages of the green transition and require additional time and…

ExxonMobil welcomes the opportunity to provide input into this call for evidence. We strongly support the principle that operators are allowed to provide verified installation specific Embedded Emissions (EE) values for use by importers (instead of (country-specific) default values) as this will provide operators with an incentive to reduce EE of their products which is an important objective of the CBAM regulation.

Subject: Commentary on the European Commission's Call for Evidence for the Carbon Border Adjustment Mechanism (CBAM) Implementing Acts on Methodology for Calculating Embedded Emissions (Article 7) The Thailand Greenhouse Gas Management Organization (Public Organization) (TGO) would like to extend its warm appreciation to the European Commission for initiating the official consultation on the implementing acts for…

As a steel producer outside the EU, we understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities involving the iron and steel production sector, especially for integrated plants on…

EFDA represents the interests of the European fastener distributors. We welcome the fact that interested parties have the opportunity to comment on the issues raised. However, we note that the Commission made this call far too late.

An Italian company exports steel sheets and steel fittings to a non-EU company on a subcontract basis. The number of exported parts is significant. The non-EU company assembles, welds, and paints the material, producing tanks that are then imported by the Italian company. The non-EU company invoices only the processing service.

Call for Evidence for an Impact Assessment 24 September 2025 Carbon Border Adjustment Mechanism (CBAM) CBAM implementation: rules on the methodology for calculating emissions embedded in CBAM goods; rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation; rules on the deduction of the carbon price paid in a third country The International Tracking Standard Foundation welcomes the adoption…

Dear Sir/Madam, on behalf of Enertrag SE, please see below a couple of comments to be taken into consideration for the Implementing act on methodology, in particular on the issue of "Calculating direct embedded emissions", "Determining embedded emissions for electricity" and "Determining embedded indirect emissions". 1.

The Polish Steel Association, supporting EUROFERs position, welcomes the EUs efforts to implement CBAM as a tool to reduce carbon leakage and ensure fair competition. For the mechanism to be effective, several adjustments are needed: During the transitional phase (e.g.

Below we set out in the attached document all the issues that would guide us to be clarified by this Commission, as we are very close to the date of entry into force of this Regulation and there are still very many doubts as to its actual application.

Filed in Spanish · English published by the European Commission

Evident, the registry operator and framework manager for the International Renewable Energy Certificate (I-REC(E)), welcomes the opportunity to contribute to the European Commission's effort to operationalise the Carbon Border Adjustment Mechanism.

Although not currently in the inclusive sector in the studies in the CBAM field, considering that our sector will be included in the short or medium term due to the involvement of our stakeholders in the relevant mechanism, the creation of an information platform and country-based workshops on these stakeholder sectors and the establishment of global collaborations similar to consortiums will accelerate the…

This initiative will establish the methodology to be applied during the definitive period of the CBAM, starting on 1 January 2026. The methodology will include the following components: The determination of direct embedded emissions based on actual emissions data The determination of embedded emissions from electricity The determination of indirect embedded emissions The use of default values for goods other than…

Steelinvest Group, a global trading company headquartered in Antwerp, fully acknowledges the importance of the Carbon Border Adjustment Mechanism (CBAM) in addressing the risk of carbon leakage and ensuring that imports into the EU face a level playing field with domestic production.

Jingzhe Ditan hereby submits its views on the evolving methodology of the Carbon Border Adjustment Mechanism (CBAM) for the definitive phase commencing on 1 January 2026. The accompanying paper sets out our principal reservations regarding the current approach, the related economic exposure, and our proposals aimed at ensuring a fair and workable framework.

It is valuable to our business that the EU commission default coefficients can be used from 1.1.2026. Many suppliers we work with still do not have this data available. We absolutely are not able to provide per product CO2 coefficients due to lack of data on supplier end. Per supplier CO2 coefficients should remain for 2026-2028.

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: if there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…

Regarding the calculation of heat and electricity, we have the following question: If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated?

A key challenge is the absence of a common global standard for monitoring and reporting emissions. Today, each country uses its own rules, which makes it difficult to compare imported products fairly and risks creating unjustified competitive advantages or disadvantages. Another problem relates to the reliability of data reported by companies, especially those outside the EU.

Filed in Italian · English published by the European Commission

CELSA Group, as one of Europes leading steel producers, welcomes the opportunity to contribute to the consultation on the Carbon Border Adjustment Mechanism methodology for the definitive period starting on 1 January 2026. CELSA Group strongly supports enhancing the Carbon Border Adjustment Mechanism (CBAM) to ensure robust protection against carbon leakage.

We expect that the benchmark values for commodities under the CBAM mechanism will support companies that are striving to reduce their own GHG emissions by enabling to report installations actual values and that no default values for location/country will apply. The rules for free allocations under the CBAM should reflect rules applied under the EU ETS.

Feedback to the European Commission CBAM Implementing Acts 1. Distortion of competition due to CN 7314 As EU producers of gabions, we use galvanized steel wire (CN 7217) as our main input. Wire is covered by CBAM. From 2026 we will be required to surrender CBAM certificates for the embedded emissions of the imported wire and bear the associated cost.

Gerber Steel GmbH respectfully submits its position on the initiative Carbon border adjustment mechanism (CBAM) methodology for the definitive period starting on 1 January 2026. The attached statement outlines in detail our concerns regarding the current methodology, the economic risks involved, and our recommendations for a fair and practicable approach.

1. Will imported goods from EU precursors (which have paid carbon taxes under the EU ETS) be included in CBAM calculations? Example: Oxide pellets imported from EU countries such as Sweden, which have paid taxes under the EU ETS, are used as raw materials by a steel company in Egypt. Will these oxide pellets be considered in the CBAM calculation for the Egyptian steel company? 2.

Good day, I believe that the methodology for calculating emissions is difficult to verify by third parties and unfortunately voted to collect a new duty that will make Europe less competitive with the rest of the world again, which will not comply with these requirements. The result will be an isolation of our economy, a new economic earthquake that will put in great difficulty, those who are already today.

Filed in Italian · English published by the European Commission

This initiative will define the methodology for the final CBAM period starting on 1 January 2026, which will determine: direct embedded emissions based on actual emissions embedded emissions of electricity and indirect embedded emissions and default values for goods other than electricity, to be used when embedded emissions are not based on actual emissions.

Filed in Italian · English published by the European Commission

1. As regards the deadline for submitting the CBAM annual declaration, we consider it essential to allow sufficient time for the collection of verified declarations from suppliers. Given the time needed to collect the primary data, prepare the CBAM declaration and carry out the external verification, we consider that a period of five months (until 31 May as currently defined by the Regulation) is too short…

Filed in Romanian · English published by the European Commission

During a transitional period (e.g. until 2030), the CBAM levy of CBAM steel goods (i.e. customs codes as of 7205) should be based on the default values of the country of origin (based on the most carbon-intensive production route) in order to avoid resource shuffling.

Being a very small company of only 5 employees, complying with CBAM is a heavy burden and potential risk of future penalties. Many suppliers have different views on CBAM scopes and/or the impact on their own future business. But some could simply stop exporting to Europe. Going back to default values per region would help a lot.

ASSOFERMET expressed its strong opposition to extending, at the final stage of the CBAM, the application of indirect emissions to goods in the steel and aluminium categories. Such an extension would create an additional administrative and financial burden for economic operators, in particular for undertakings in the distribution and processing chain, which have no direct control over the energy mix used in the…

Filed in Italian · English published by the European Commission

While reporting based on actual values is theoretically preferable, it often proves challenging in practice due to variations in supply chains and the complexity of products and materials. To facilitate reporting using standardized values, we propose the publication of country or region-specific tables containing standard values for each material.

As a medium-sized manufacturing company, CBAM presents us with significant organizational, technical, and financial challenges. The key issues lie in sourcing data from third countries, establishing internal processes and systems, and managing the financial burden of purchasing certificates.

As power trader, Danske Commodities A/S, based in Denmark, have several borders where we flow/import electricity towards EU. The CBAM regulation in it's current state will affect cross-border trading negatively as it will impose tariffs and administration burdens to these operations.

The Federation of Norwegian Industries supports the introduction of CBAM in the EU and Norway. It is in the interest of both Norway and the EU that CBAM functions as intended, providing companies competing globally with effective protection against carbon leakage and contributing to increased profitability for production with a low carbon footprint.

Norsk Hydro advocates for strengthening CBAMs methodology to align with the EU ETS by closing loopholes, assigning emissions to scrap, keeping indirect emissions out of scope for aluminium, and ensuring electricity rules remain enforceable and realistic, with the core principle that imported CBAM goods should bear the same carbon costs as if produced in Europe, without incentives to circumvent the system.

There shall be mentioned that import of complex CBAM goods can be reported only with final emission values (sum of precursor + production site emissions). Emissions of precursors (= also CBAM goods) cannot be described separately in portal for transitionary period. The ongoing lack of a valid formula for pricing emissions of CBAM goods from 2026 on is critical for companies and their customers.

As stakeholders in the cement industry, we would like to raise a critical point regarding the methodology used for CBAM cost calculations, particularly in relation to benchmark values. Under the EU ETS framework, benchmark values of 0.957 tCO/t for white clinker and 0.693 tCO/t for grey clinker have been established.

a. With regard to the deadline set for the submission of the CBAM annual declaration, it is essential to have a sufficient period of time to collect verified suppliers’ declarations. Given the time required to obtain primary data, draw up the declaration and carry out the external verification, we consider that the current deadline of 31 May under the Regulation is limited, especially in the absence of clear…

Filed in Spanish · English published by the European Commission

1- on the deadline for sending the CBAM annual declaration, we consider it essential to have adequate time to collect verified declarations from suppliers. Given the time needed for the collection of primary data, the preparation of the CBAM declaration and the external verification, we believe that five months (until 31 May, as currently defined by the Regulation) is the short time, taking into account the lack of…

Filed in Spanish · English published by the European Commission

(1) on the deadline for sending the annual CBAM declaration, we consider it essential to have adequate time to collect the verified declarations of different suppliers. Given the time taken to collect primary data, draw up the CBAM declaration and external verification, we believe that 5 months (31 May – as now defined by the Regulation) is the minimum time needed, better if it were extended (2) As regards the…

Filed in Italian · English published by the European Commission

The Republic of Korea notes the Commissions ongoing work in drafting the methodology to calculate embedded emissions for the definitive implementation of CBAM. The complexity of the methodology may itself create technical barriers to trade.

FuelsEurope welcomes the European Commissions consultation of stakeholders on the Implementing Regulation on the CBAM methodology for the definitive period starting on 1 January 2026. FuelsEurope believes that, as indirect costs are not directly related to indirect emissions, the carbon leakage risk associated with indirect emissions costs should be addressed through an EU-wide harmonised system of indirect cost…

Calculation of direct embedded emissions: For the cement sector, the European Emissions Trading Monitoring and Reporting Regulation and its guidance documents are the relevant reference for determining direct emissions. In order to achieve a level playing field, the application of the same rules, conditions and definitions as for installations in the European Emissions Trading System is an important prerequisite.

Filed in German · English published by the European Commission

we are Arab Carbon Special Steel Company is honored to participate in the European Union's survey, in addition to the Carbon Scope Adjustment Mechanism (CBAM), by leapfrogging its international commitments for sustainability and reducing carbon emissions, and its keenness to align its operations with global environmental requirements.

we are Arab Carbon Special Steel Company is honored to participate in the European Union's survey, in addition to the Carbon Scope Adjustment Mechanism (CBAM), by leapfrogging its international commitments for sustainability and reducing carbon emissions, and its keenness to align its operations with global environmental requirements.

The CBAM reporting system has been complicated and very bureaucratic. In particular, the fact that the calculation of emissions is entrusted to suppliers, but the responsibility for the data lies with the importer, creates great difficulties, especially for small and medium-sized companies. Obtaining emissions data from many suppliers has been very complex.

Filed in Italian · English published by the European Commission

Carbon border adjustment mechanism (CBAM): 1. Increase the load on Egyptian industry especially Cement industry and may be a barrier for exporting cement to EU countries. 2. The verification and validation is not clear yet. 3. High cost for European verification and validator 4. It is necessary to have Egyptian verifiers and validators. 5.

Our feedback proposes integrating the CBAM implementing acts with the European Trade Indexes Registry (EUTIR) and eIDAS 2.0 to transform CBAM from a compliance mechanism into a trusted digital trade infrastructure.

Please provide proper importance on ensuring a four-month window for the CBAM reporting process. The realistic timeframe, based on real processes, the CBAM declaration for the year 2026 should be submitted via the platform by April 2027, with the corresponding CBAM tax payment due by June 2027.

We would like to express our strong concern regarding the absence of published benchmarks for the calculation of CBAM obligations for the definitive period starting on 1 January 2026. As of 1 October 2025, we will already be purchasing steel for delivery to the EU in early 2026. For these imports, we will be required to purchase and surrender CBAM certificates in 2027, once the system is operational.

This is really difficult to achieve, as it is difficult to obtain such information, for example from China, or to explain to them what Info is needed from them. It would be really commendable if more tools, guidance and training were also provided for the necessary reporting.

Filed in Finnish · English published by the European Commission

Customs will receive all information on the product to be imported with the tariff code and declaration of the goods. The question is why the CBAM authorisation makes everything more burdensome? Customs should and will certainly trigger a requirement automatically when the limit values are reached. This would make it less bureaucratic.

Filed in German · English published by the European Commission

The CBAM Regulation applies to goods listed in Annex I in the Regulation originating in a third country. In Article 2, section 3 it is stated that when the intrinsic value of such goods does not exceed, per consignment, the value specified for goods of negligible value as referred to in Article 23 of Council Regulation (EC) No 1186/2009, there is no need to file a report.

Why will the future CBAM report not only use default values from 2026 onwards. Rather than keeping a simple method for all, complicated calculation methods are proposed, together with the control of accredited auditors. The customs administration receives the relevant data (HS code and quantity) automatically for each import declaration.

Filed in German · English published by the European Commission

Thank you for the opportunity to provide feedback. As the import handler for our small company, CBAM reporting falls under my duties. I manage nearly 100 suppliers outside the EU and gathering CBAM data regarding our iron/steel and aluminum products has been a significant burden.

On emission methodology, it is crucial that the secondary technical regulations governing the calculation of embedded emissions are finalized without delay. Currently, data from supplier countries is often incomplete or unreliable, undermining the accuracy of reporting.

Challenges & Needs related to CBAM in Privet Sector (Fertilizers) 1. The company has no preliminary estimate of CBAM certificate costs, creating financial uncertainty and raising concerns about losing competitiveness against countries like Russia or the Gulf. 2. There are no specific projects (CCUS, Solar) in place, and the company struggles to access international finance such as the EU Green Deal or Climate Funds.

Calculating emissions for a particular product type (or group of products covered by one CN code) may require monitoring one or more production lines (or installations) within a production facility. Manufacturers must measure media consumption per product type, which requires installing meters or flow meters on each production line.

As Sustainabilios, we provide consultancy services to a wide range of industrial companies in Türkiye on carbon management and CBAM preparedness. Drawing on our field experience, we would like to respectfully submit the following observations and recommendations: Data Access and Quality In Türkiye, particularly for small and medium-sized exporters (SMEs), accessing reliable and comprehensive data for embedded…

Buongiorno, the following feedback is issued by the Renato Mazzamauro, the direct representative of Leonardo SPA: The CBAM has proven to be a cumbersome and bureaucratic tool from the outset. The emissions calculation system delegated to their suppliers, but with the veracity of the data under their responsibility, is a bureaucratic brake even for largely structured companies.

Filed in Italian · English published by the European Commission

1. Embedded Emission Calculation Methods for CBAM Products With the full implementation of CBAM starting in January 2026, it is essential that the methodologies for calculating embedded emissions are standardized, transparent, and aligned with internationally recognized frameworks such as ISO standards and the GHG Protocol.

I would like to highlight the significant complexity associated with collecting both direct and indirect emissions data from suppliers, particularly for businesses purchasing relatively small volumes of covered goods.

1. One of the key risks to the legality of CBAM under fair trade rules is the unequal treatment of European and non-EU operators in certain industries. This disparity is particularly evident in industrial processes not covered by the EU ETS. For instance, products from the aluminium extrusion industry (including powder coating, anodizing, machining, etc.) are classified as "aluminium products" under CBAM.

The following aspects of the CBAM methodology remain unclear in practical implementation: 1. Clarify the calculation method for source flows in the production process and installation level: If an installation contains both balance-based and standard-based production processes, should the materials be calculated separately based on the production process method (balance-based and standard-based) when determining…

The following aspects of the CBAM methodology remain unclear in practical implementation: 1. Clarify the specific content included in the boundaries of production processes: Currently, the definition of the boundaries for each production process is not clear enough.

I'm an Italian consultant who supports companies in preparing CBAM declarations. The emissions calculation mechanism is complicated, suppliers struggle to provide data, and the values risk being subject to significant errors.

The methodology to be adopted by the European Commission in 2026 should avoid becoming a mere accounting adjustment and ensure environmental integrity, social justice and industrial coherence. The official call document outlines three technical axes: Calculation of direct and indirect embedded emissions (including electricity). Setting default values against actual emissions.

Filed in Spanish · English published by the European Commission