The European Commission’s technical study on indirect emissions under the Carbon Border Adjustment Mechanism (CBAM) was published through DG TAXUD on 8 June 2026. The study sets out three policy questions covering default emission factors for indirect emissions, conditions for claiming actual indirect emissions, and whether indirect-emissions coverage should expand to additional CBAM sectors.
The study’s focus shifts the readiness question for exporters from documentation to plant capability. It raises a physical evidence requirement: whether a facility’s electrical architecture can support the electricity claim used in the CBAM number.
Indirect emissions are calculated by multiplying electricity consumed during production by an applicable electricity emission factor. The Commission FAQ indicates that the electricity emission factor may be based on the grid supplying the electricity or, where allowed, an actual electricity emission factor.
Electricity evidence requirements for indirect emissions calculations
The calculation method creates an evidence chain that extends beyond site-level reporting. A plant must be able to identify what electricity was consumed across installation, production process, product route, auxiliary system, and where possible, CBAM product category.
Time resolution is also part of the evidence burden. Monthly data may not be sufficient when PPA matching, onsite generation settlement periods, or verifier sampling require stronger time granularity.
Evidence must also cover the source of electricity. Grid import, onsite generation, behind-the-meter renewable assets, direct technical links, PPAs, supplier contracts, and certificate systems can each create different documentation requirements.
Where multiple products and routes share equipment or serve both EU and non-EU markets, allocation becomes a technical risk point. The method used to allocate electricity across products and boundaries is therefore tied to how claims can be defended under CBAM.
Verification readiness depends on more than statements. Supplier statements and green certificates may not be sufficient if metering, contractual arrangements, and operational records are weak.
Default values under CBAM and the impact of weak electricity data
The definitive-period CBAM regime includes default values for certain parameters. The Commission’s legislation and guidance indicate that default values have been published and that legally binding values are set out in Commission Implementing Regulation (EU) 2025/2621.
The Commission FAQ further explains that authorised CBAM declarants may use default values for CBAM goods other than electricity when verified actual embedded-emissions data are not available. It also states that default values are country- and year-specific.
For exporters, weak electricity evidence can affect which approach an importer uses. If electricity data cannot be supported with adequate proof of consumption and origin, it may push the importer toward default values rather than verified actual figures.
PPA claims for actual indirect emissions and contract evidence design
The study’s second policy question addresses actual indirect-emissions claims through direct technical links, PPAs, and verification. This creates an opportunity for renewable developers, industrial exporters, and EU buyers seeking to support lower indirect-emissions results with evidence.
The same framework also creates a constraint on how “green” contracts translate into CBAM-ready claims. A generic green electricity contract may support sustainability messaging but does not automatically meet the evidentiary logic required for CBAM.
Earlier transitional-period guidance allowed actual electricity emission factors where there is either a direct technical link between the production installation and the generation source or a PPA between consumer and producer for an equivalent amount of electricity. In that context, a CBAM-relevant PPA needs engineering around evidence rather than only pricing terms.
The contract evidence set described includes metering points, generation data, delivery shape, settlement records, guarantees of origin or equivalent certificate controls, matching methodology, balancing treatment, and verifier access. The intended outcome is described as CBAM-verifiable electricity, not simply “green electricity.”
Scope signals for Serbia and Southeast Europe exporters
For Serbia, the Western Balkans, and Southeast Europe, many industrial exporters sell steel, aluminium, cement, fertilisers, hydrogen-related products, components, or precursors into the EU market. These exporters operate in power systems where grid emission intensity, renewable procurement structures, and metering maturity vary significantly.
The current CBAM FAQ states that scope is limited to direct emissions for iron/steel, aluminium, and hydrogen. It also states that cement, fertilisers, and agglomerated iron ore must declare both direct and indirect emissions.
The FAQ further indicates that indirect emissions are taken into account only for CBAM goods where indirect emissions fall within scope. The Commission’s study nonetheless examines whether coverage could extend to additional CBAM sectors beyond the current scope.
Engineering tasks before verification: metering architecture review
A reporting workflow alone does not address whether physical and digital plant evidence exists for verification. Before verification can occur, someone must establish whether the facility can produce required metering and operational records as an engineering task.
An electricity-evidence review is described as examining the plant single-line diagram; grid import and export interfaces; transformer and substation metering; process-level and line-level meters; SCADA/EMS systems; meter-data systems; onsite generation metering; PPA settlement data; guarantees of origin or equivalent certificate controls; production-process boundaries; and how electricity allocation is handled by CN code, product route, and EU export volume.
The review also includes reconciliation between MWh consumed and tonnes produced. It covers identification of evidence gaps that could force reliance on default-value approaches instead of verified actual inputs.
Clarion.Engineer service layers for CBAM electrical readiness
Clarion.Engineer positions CBAM readiness as a technical infrastructure problem built around four layers. The first layer is a CBAM electrical metering architecture review, mapping grid connection details including substations and transformers alongside main meters, process meters, auxiliary loads, self-generation arrangements, direct links, PPA interfaces, and excluded loads.
The output described is a CBAM meter hierarchy indicating which meters support which production processes and where evidence gaps exist. The second layer develops a product-level allocation model linking electricity allocation to production boundaries and product categories for complex plants with shared equipment or multiple routes.
The third layer translates PPA documentation into an engineering evidence package aligned with CBAM requirements. It reviews whether PPA claims are supported by generation evidence plus metering records, settlement data, delivery periods, matching logic, certificate treatment details, and verifier access arrangements.
The fourth layer prepares an importer-facing technical data room intended for verifier use. The Commission FAQ states importers must be authorised CBAM declarants from 1 January 2026, with the first annual declaration due by 30 September 2027 together with certificate surrender; this drives structured evidence demands from non-EU suppliers.
The described data room contents include meter registry information; monthly readings; SCADA extracts; PPA records; certificates; production allocation logic; emission-factor assumptions; reconciliation checks; and gap-closing actions. The output is described as a verifier-facing CBAM electricity evidence dashboard.