Cement is one of the most carbon-intensive materials in the world, and the EU is the world’s second-largest cement producer. CBAM’s coverage of cement and clinker imports is designed to protect EU cement manufacturers who have invested in decarbonisation while ensuring imported cement faces equivalent carbon costs. For importers, the compliance obligations are technically demanding — cement emissions involve unique chemistry that sets it apart from every other CBAM product category.
CBAM covers cement products including clinker, Portland cement, aluminous cement, and hydraulic cements. Cement’s embedded emissions primarily come from two sources: the calcination of limestone (process emissions that cannot be eliminated through fuel switching) and the burning of fuels in the kiln. Typical embedded emissions range from 0.3 to 1.0 tonnes of CO2 per tonne depending on cement type and clinker ratio. Importers must report these emissions and purchase CBAM certificates — but accurately calculating cement emissions requires deep understanding of production chemistry, clinker ratios, and supplementary materials.
Key Takeaways
- Cement process emissions from limestone calcination account for roughly 60% of total CO2 — they cannot be eliminated through fuel switching, making cement uniquely hard to decarbonise
- Clinker has higher embedded emissions than finished cement due to dilution with supplementary materials
- The clinker-to-cement ratio is the key variable affecting CBAM costs, but verifying it requires specialist knowledge
- Default values for cement can be significantly higher than actual producer data — but obtaining accurate data requires understanding the production process
- CBAM intersects with the Construction Products Regulation, creating overlapping compliance obligations that must be managed together
Which Cement Products Are Covered
CBAM covers the following cement categories:
- Clinker — the primary intermediate product in cement production
- Portland cement — including ordinary Portland cement (OPC) and blended variants
- Aluminous cement — high-alumina cement used in refractory applications
- Other hydraulic cements — including slag cement and pozzolanic cement
Product classification in cement sounds straightforward, but in practice it requires attention to detail. Blended cements, composite cements, and products that combine cement with supplementary cementitious materials can raise classification questions that affect both scope determination and emissions calculation. Misclassification can mean either unnecessary compliance costs or — worse — missed reporting obligations.
Why Cement Emissions Are Uniquely Complex
Cement production generates CO2 from two distinct sources, and this dual nature creates compliance challenges that differ fundamentally from steel, aluminium, or other CBAM products.
Process Emissions: The Unavoidable 60%
When limestone is heated in a kiln, a chemical reaction — calcination — releases CO2 that accounts for approximately 60% of cement’s total emissions.
This matters enormously for CBAM compliance because these emissions cannot be reduced through operational improvements, fuel switching, or renewable energy. They are inherent to the chemistry of cement production. Even the most efficient cement plant in the world still produces substantial CO2 from calcination alone — and correctly quantifying these process emissions under the EU’s prescribed methodology requires detailed knowledge of the raw material composition, not just production volumes.
Fuel Emissions: The Variable 40%
The kiln must reach extreme temperatures to produce clinker. The fuel burned to achieve this generates the remaining 40% of emissions, varying significantly between producers depending on their fuel mix, kiln efficiency, and use of alternative fuels.
The combination of fixed process emissions and variable fuel emissions makes cement CBAM calculations technically demanding. You cannot assess a cement producer’s emissions profile without understanding both the chemistry and the specifics of their kiln operations — and the EU’s methodology for apportioning emissions across these sources involves calculation steps that interact in non-obvious ways. Get in touch if you need support translating your suppliers’ production data into compliant CBAM declarations.
Embedded Emissions Across Cement Products
| Product | Typical Emissions (tCO2/t) | Key Factor |
|---|---|---|
| Clinker | 0.8–1.0 | Highest intensity — undiluted |
| Portland cement (OPC) | 0.7–0.9 | ~95% clinker content |
| Blended cement (CEM II) | 0.5–0.7 | 65–94% clinker, rest supplementary materials |
| Slag cement (CEM III) | 0.3–0.5 | 5–64% clinker, rest blast furnace slag |
The clinker-to-cement ratio is the single biggest variable affecting CBAM costs for finished cement. But verifying a supplier’s actual clinker ratio — rather than relying on product labels or general specifications — requires understanding of cement classification standards and access to production data that suppliers may not readily share.
CBAM Costs for Cement Importers
At €75/tCO2:
| Product | Emissions | CBAM Cost/Tonne |
|---|---|---|
| Clinker | 0.9 tCO2/t | ~€68 |
| OPC | 0.8 tCO2/t | ~€60 |
| Blended cement | 0.6 tCO2/t | ~€45 |
| Slag cement | 0.4 tCO2/t | ~€30 |
While per-tonne costs are lower than steel or aluminium, cement is imported in very large volumes, making total CBAM obligations significant for major importers. And as ETS free allowances phase out, these costs will escalate substantially through 2034.
The financial difference between using accurate supplier data and relying on default values can be considerable — particularly for importers of blended or slag cements where actual emissions are well below the defaults. But realising those savings requires data that meets the EU’s verification standards, which brings its own challenges.
The Data Challenge in Cement
Obtaining accurate, CBAM-compliant emissions data from cement producers presents several interconnected difficulties:
- Process emissions calculation depends on raw material composition — specifically the calcium carbonate content of the limestone feed, which varies between quarries and is rarely disclosed in standard product documentation
- Fuel mix complexity — modern cement plants use blends of conventional fuels, waste-derived fuels, and biomass, each with different emission factors and accounting treatments under the EU’s prescribed methodology
- Clinker ratio verification — the key cost variable, but verifying it independently requires production data that goes well beyond standard product specifications
- System boundaries — determining which emissions fall inside and outside the CBAM system boundary requires careful interpretation of a regulation that was not written with cement importers in mind
Each of these areas involves judgment calls that carry direct financial consequences. Getting one boundary wrong or misapplying one emission factor can shift your CBAM obligation by tens of thousands of euros annually. This is precisely the kind of technical compliance work where our CBAM specialists add the most value — talk to us if your data collection process feels uncertain.
Connection to the Construction Products Regulation
For cement importers, CBAM compliance intersects with the new Construction Products Regulation (EU) 2024/3110, creating overlapping obligations that need coordinated management. The CPR requires environmental performance data — including carbon data — for construction products, and Environmental Product Declarations (EPDs) contain information that overlaps with but does not map directly onto CBAM reporting requirements. Both regulations are evolving simultaneously.
The interaction between these two frameworks is where many cement importers encounter unexpected compliance gaps. Trying to manage CBAM and CPR separately leads to duplicated effort, inconsistent data, and increased risk of errors that trigger enforcement action under one or both regulations. An integrated approach is essential — read more about CPR requirements, or contact us to discuss how these obligations affect your specific import portfolio.
How Clearscope Helps Cement Importers
Cement CBAM compliance requires a combination of regulatory expertise, understanding of cement production chemistry, and practical experience in supplier data management. Clearscope brings all three.
Our CBAM compliance services for cement and construction materials importers include:
- Product classification and scope determination — Confirming which of your cement products fall within CBAM scope, including complex cases involving blended and composite cements
- Emissions quantification — Calculating embedded emissions using the correct treatment of process emissions, fuel emissions, and clinker ratios for your specific products and suppliers
- Supplier data programmes — Structured engagement with cement producers to obtain installation-level data that meets EU verification standards, including navigating the technical specifics of raw material composition and fuel mix reporting
- CPR-CBAM integration — Aligning your CBAM compliance with Construction Products Regulation requirements to avoid duplication and ensure consistency across both regulatory frameworks
- Cost modelling and strategic planning — Projecting your CBAM certificate obligations under different carbon price scenarios and the allowance phase-out schedule, informing procurement and sourcing decisions
- Ongoing compliance management — Maintaining accurate CBAM reporting as the regulation evolves and your supply chain develops
Cement’s unique emissions chemistry, the overlapping CPR obligations, and the data challenges inherent in the supply chain make this one of the more demanding CBAM product categories to manage correctly. Contact us for a cement-specific CBAM assessment.
Frequently Asked Questions
Does CBAM apply to ready-mixed concrete?
No. CBAM currently covers cement products (clinker, Portland cement, etc.) but not downstream products like ready-mixed concrete or precast concrete elements. However, the embedded emissions in the cement component of concrete would be covered if that cement is imported.
Can cement producers reduce their CBAM-relevant emissions?
Partially. Fuel-related emissions (about 40%) can be reduced through alternative fuels and efficiency gains. Process emissions from calcination (about 60%) are chemically unavoidable with current technology. This irreducible floor is what makes cement CBAM calculations unusually sensitive to methodology and data quality.
How does the clinker-to-cement ratio affect CBAM costs?
Lower clinker ratios mean lower embedded emissions and lower CBAM costs. But verifying a supplier's actual clinker ratio — and correctly translating it into emissions under the EU's methodology — is more complex than applying a simple percentage reduction. Errors here directly affect your CBAM certificate obligation.
Are there carbon prices on cement in non-EU countries?
Some countries have carbon pricing mechanisms covering cement production. Carbon prices paid abroad can in principle be deducted from CBAM obligations, but the documentary evidence requirements are stringent and vary by jurisdiction. This is an area where the regulatory detail matters enormously — small errors in offset claims create enforcement exposure.