CBAM by sector

CBAM and Cement

Cement is one of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). If you import cement or clinker, you may have CBAM obligations once your annual imports cross the 50-tonne threshold. For cement, both direct and indirect emissions are counted, reflecting how carbon-intensive cement-making is. This page explains what is covered and what to do.

Cement

Direct + indirect emissions · 50 t threshold

TL;DR

  • Cement is in scope under Regulation (EU) 2023/956, defined by the CN codes in Annex I.
  • Covered products include cement clinker, Portland and other cements, and aluminous cement.
  • Both direct and indirect (electricity) emissions are counted for cement.
  • Cement counts toward the cumulative 50-tonne annual de-minimis threshold; importers under 50 tonnes/year of covered goods are exempt.
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In scope

What CBAM covers for cement

  • Cement clinker.
  • Portland cement (white or coloured, and other Portland types).
  • Aluminous cement.
  • Other hydraulic cements listed in Annex I.

Annex I lists each product by its CN code. Because cement is heavy, even modest volumes can cross the 50-tonne threshold quickly — confirm scope by matching your customs code.

These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.

Emissions

How embedded emissions are counted

Both direct and indirect emissions are counted. For cement, CBAM counts both direct emissions (largely the process CO₂ released when limestone is calcined to make clinker) and indirect emissions from the electricity used in production. Regulation (EU) 2023/956

Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.

The 50-tonne threshold

Does the de-minimis exemption apply?

Cement counts toward the 50-tonne threshold

Cement counts toward the cumulative 50-tonne annual net-mass threshold (combined with steel, aluminium and fertilisers). Because cement is dense, importers cross 50 tonnes at relatively low volumes — track your cumulative mass carefully. 2025 Omnibus, Regulation (EU) 2025/2083

Use the scope checker to confirm your position.

The hard part

The hard part for cement

  • Both direct and indirect emissions count, and cement’s process emissions (from calcining limestone) are unavoidably high.
  • The threshold is easy to cross: cement is heavy, so even small shipments add up to 50 tonnes quickly.
  • Getting verified installation data from cement plants in origins new to emissions reporting.
  • Tracking cumulative tonnage across all four mass-counted sectors to know when you cross 50 tonnes.

What to do

What to do for cement

  1. Confirm scope by matching your cement and clinker product lines against the CN codes in Annex I.
  2. Add up your annual net mass across steel, aluminium, cement and fertilisers — cement’s weight means you may cross 50 tonnes sooner than expected.
  3. Gather both direct and indirect emissions data from suppliers, or use the published default values.
  4. If you import above the threshold, become an authorised CBAM declarant (or use an indirect customs representative who is) via the CBAM Registry.
  5. Gather embedded-emissions data from your suppliers, or fall back to the published default values, then file your annual CBAM declaration and surrender certificates by 30 September of the following year.

For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.

FAQ

Cement and CBAM: common questions

Is cement covered by CBAM?
Yes. Cement clinker, Portland and other cements, and aluminous cement are listed in Annex I of Regulation (EU) 2023/956. Confirm your specific product by its CN code.
Are both direct and indirect emissions counted for cement?
Yes. Cement is one of the two sectors (with fertilisers) where CBAM counts both direct emissions from production and indirect emissions from the electricity used in production.
How quickly do cement importers cross the 50-tonne threshold?
Quickly — cement is dense, so 50 tonnes is a modest volume. Cement counts toward the cumulative annual mass threshold alongside steel, aluminium and fertilisers, so track your total carefully.
When do cement importers have to comply with CBAM?
The definitive period began on 1 January 2026. If your annual imports cross the 50-tonne threshold you must be (or use) an authorised CBAM declarant. The first annual declaration and surrender for 2026 imports is due 30 September 2027.

Get ready for CBAM

Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.

Get the CBAM Checklist

This is guidance, not legal advice

This is guidance to help you understand how CBAM applies to cement, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. Some details remain subject to pending implementing acts; where the rules are unsettled we say so.

Sources

  1. [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
  2. [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
  3. [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
  4. [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026

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