Iron, steel and aluminium producers
Businesses exporting to the European Union in product groups within the mechanism's scope. In these groups, buyer demand has emerged earliest and most concretely.
CUSTOM SOFTWARE · CBAM AND EMISSIONS
CBAM Embedded Emissions Calculation: The Data Your Buyer Will Ask For
We build a layer that calculates the embedded emissions of the products you export to the European Union at plant, line and batch level. It combines production, energy and raw material data and produces the result in a form your buyer will accept and a verifier can trace.
The definitive period of the carbon border adjustment mechanism began on 1 January 2026. Under the mechanism, the legal obligation sits with the importer in the European Union; the producer in Türkiye is not the obligated party but the data supplier. The first declaration and certificate surrender for 2026 imports is due on 30 September 2027. Getting this picture right matters, because approaches that present the subject as a legal obligation on you are both wrong and a source of needless panic.
Even so, the outcome is binding on the producer in practice. Your buyer in Europe will ask you for embedded emissions data per product in order to work out what they will pay; if you cannot provide it, default values kick in — and those values are usually worse than your actual production performance. In other words, the cost of not providing data feeds straight into your product's price competitiveness. Some buyers have already made this data a supplier selection criterion.
The calculation itself is production engineering, not accounting. A product's embedded emissions emerge from evaluating fuel and electricity use, process emissions, the emissions carried by purchased intermediates and production volumes together. Where the system boundaries are drawn, how shared site consumption is allocated across products, and which data is measured versus assumed directly determine the result. The real task is therefore not producing a number but being able to show how that number was produced.
The layer we build does exactly that: it combines production tracking data, energy meters, fuel consumption and emissions information collected from suppliers; it runs the calculation with a defined method and keeps the inputs behind every result traceable. Verification is the job of an independent verifier and we do not take that role; what we produce is a data set with a known source that can be put in front of the verifier. The details of the regulation and the methodological choices are settled together with your expert, and it is their decision we write into the system.
Who is it for?
Who is CBAM Embedded Emissions Calculation and Reporting a good fit for?
Cement, fertiliser and hydrogen producers
Sites whose production is dominated by process emissions. Here the calculation cannot be built on energy consumption alone; process data has to enter the system too.
Producers outside the scope whose buyers ask for data
Factories whose products are not directly in scope but whose customers request supplier data for their own accounting. This demand is spreading independently of the scope list.
Manufacturers processing purchased intermediates
Businesses using bought-in intermediate products in their own production. In that case, collecting emissions data from suppliers is a mandatory part of the calculation, and the collection process is a piece of work in its own right.
What we build
What we deliver within CBAM Embedded Emissions Calculation and Reporting
Combining production, energy and fuel data
Production volumes, electricity and fuel consumption and process data are combined on the same timeline. Measured data and default data are flagged separately; which items rest on measurement is the first indicator of how reliable the result is.
Defining system boundaries and allocation rules
Which parts of the site are in the calculation, how shared consumption is allocated across products and how by-products are treated are written into the system as defined rules. Rules are not buried in code; when they change, past calculations are preserved and which calculation used which rule version stays on record.
Calculation at product, line and batch level
Emissions do not stop at the site total; they break down to product group, line and — where needed — batch. The same product giving different results on different lines or in different periods is normal, and seeing that difference is the information improvement depends on.
Supplier emissions data collection
Collecting data from suppliers for purchased intermediates is managed: who was asked for what, when it arrived, which period it covers. Items with no data are clearly flagged and how they are treated in the calculation stays visible.
Buyer-ready output
The result is compiled per product, in the structure your buyer expects. The output is not just a number; it includes the input items and the method it rests on, so when the buyer's question comes, there is no going back to search.
Preserving the verification trail
Which raw data, which rule version and which date every calculation was produced from is stored. When a verifier arrives, the trail they will follow is ready. As much as the calculation itself, the existence of this trail is what makes the result defensible.
Technologies
The technologies we work with
- Production and energy data integration
- Time-series data storage
- Allocation and system boundary rules engine
- Emission factor library
- Supplier data collection workflow
- Product tree and batch traceability
- Versioned calculation records
- Report and export templates
- Audit trail
Process
How we move from discovery to go-live
- 01
1. Scope and data source assessment
We map which products go to which buyers, what the buyer is asking for and which data is measured today. On this tour, most sites discover that energy and production data is not broken down finely enough for the calculation; the scope is set against that reality.
- 02
2. Closing the measurement gaps
Missing measurement points and record breakdowns are identified. If the energy side is already in place, the work is short; if not, that infrastructure is built first, because an emissions calculation run on unmeasured data collapses into a pile of assumptions.
- 03
3. Writing the method and rules
System boundaries, allocation rules and emission factors are settled together with your expert and entered into the system as definitions. We do not make the methodological choices; we make the chosen method repeatable and traceable.
- 04
4. Calculating and testing against a past period
The system is run over a past period; results are compared with earlier calculations, where they exist, and with site knowledge. Unexpected results are examined one by one; this stage usually yields the most findings about data quality.
- 05
5. Regular production and delivery routine
How often the calculation is produced, who reviews it and how it is delivered to the buyer are defined. The supplier data collection calendar goes live and the system is handed over to the team.
Frequently asked questions
Common questions about CBAM Embedded Emissions Calculation and Reporting
Is this our legal obligation?
No. The legal obligation under the mechanism belongs to the importer in the European Union; you are in the position of data supplier. But your buyer will ask you for this data, and if you cannot provide it, default values are used. Because those values are usually worse than your actual performance, the outcome feeds into your price. So the compulsion is commercial rather than legal; in effect, the difference is small.
Our consultant does the calculation — why is software needed?
Your consultant sets the method and interprets the results; the site produces the data. A manual calculation is possible for a single period, but it becomes unsustainable when it has to be repeated every period and the buyer wants product-level detail. The system runs the same method repeatably and keeps the trail of every result.
Do you do verification?
No. Verification is the job of an independent, authorised role; we do not take that role and we advise caution towards any offer that claims to. Our work is to produce a data set, with a known source and method, that can be put in front of the verifier.
We have no energy metering — what should we do first?
Building the energy side first is the right order. Most inputs to the emissions calculation are energy and fuel consumption; without that data, the calculation fills with assumptions and becomes hard to defend to the buyer. Once energy monitoring is in place, the emissions side largely uses the same data; building the two separately would be needless duplication.
We are not in scope, but our customer is asking for data.
This is increasingly common and is served by the same infrastructure. Your customer may be collecting supplier data for their own accounting or their own reporting. In practice it is sounder to decide by looking at your buyer's request rather than the scope list.
What do we end up with?
An embedded emissions calculation per product and line; a data set in which measured and default inputs are flagged separately; defined, versioned calculation rules; a supplier data collection workflow; buyer-ready reports and a complete audit trail a verifier can follow. The source code, the calculation rules and the data set produced are one hundred per cent yours.
Contact
Let us talk about your CBAM Embedded Emissions Calculation and Reporting project
In a 30-minute discovery call we listen to what you need and tell you honestly whether custom development or an off-the-shelf product is the better answer.
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