The European Commission’s technical study on indirect emissions in the Carbon Border Adjustment Mechanism was published through DG TAXUD on 8 June 2026. It sets out three policy questions: how operational default emission factors for indirect emissions should be determined; when declarants may claim actual indirect emissions, including through direct technical links, power purchase agreements and verification; and whether indirect-emissions coverage should be extended to additional CBAM sectors.
The study shifts the compliance readiness question for exporters toward physical proof of electricity use. It frames a central test for plants: whether electrical architecture can support the electricity claim used behind the CBAM number. In this approach, electricity is treated as a compliance object rather than background energy consumption.
Indirect emissions are calculated by multiplying electricity consumed during production by the applicable electricity emission factor. The Commission FAQ indicates that the electricity emission factor may be based on the grid supplying the electricity or, where CBAM rules permit, an actual electricity emission factor. The calculation method therefore depends on an evidence chain that links consumption data to the chosen factor.
Evidence requirements for indirect emissions claims
A plant needs to document what electricity was consumed across installation, production process, product route, auxiliary systems and, where possible, CBAM product category rather than only at the site gate. It also needs to establish when electricity was consumed, with monthly data potentially insufficient for PPA matching, onsite generation settlement periods or verifier sampling.
Evidence must also cover where the electricity came from, including grid import, onsite generation, behind-the-meter renewable assets, direct technical links, PPAs, supplier contracts and certificate systems. Allocation is another technical point: if one site produces multiple products, serves EU and non-EU markets, uses shared auxiliaries or runs several production routes, the allocation method becomes a risk area for the claim.
Verification readiness depends on whether supplier statements and green certificates align with underlying metering, contractual and operational evidence. This is described as a reason that CBAM readiness requires electrical metering architecture capable of supporting the claim under verification conditions.
Default values and commercial exposure
The CBAM definitive-period regime already includes default values for indirect emissions. The Commission’s CBAM legislation and guidance page states that default values have been published and that legally binding values are set out in Commission Implementing Regulation (EU) 2025/2621.
The Commission FAQ also 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 adds that default values are country- and year-specific. For exporters, weak electricity data can push importers toward defaults rather than verified actual figures.
The practical implication is that producers unable to prove both electricity consumption and electricity origin may lose the ability to defend lower embedded-emissions figures tied to indirect emissions calculations. In markets where grid carbon intensity differs from default assumptions, this can affect commercial outcomes linked to price, margin and market access.
PPAs as a route to actual indirect emission factors
The study’s second policy question focuses on actual indirect-emissions claims, including direct technical links, PPAs and verification. It identifies an opportunity for renewable developers, industrial exporters and EU buyers to structure renewable PPAs as part of a CBAM value strategy rather than only as energy procurement arrangements.
At the same time, not every green PPA is described as automatically usable for CBAM purposes because CBAM requires stronger evidentiary logic than sustainability claims alone. The Commission’s earlier transitional-period default-values approach 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.
A CBAM-relevant PPA therefore needs to be engineered around evidence requirements rather than price alone. The contract support 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 resulting product is characterised as “CBAM-verifiable electricity.”
Scope considerations for Serbia and Southeast Europe
For Serbia and Southeast Europe—covering industrial exporters selling steel, aluminium, cement, fertilisers and hydrogen-related products into the EU—the study’s focus on indirect emissions intersects with varying grid emission intensity and differing renewable procurement structures. Many exporters operate in power systems where metering maturity differs across locations used for production routes feeding EU demand.
The current CBAM FAQ cited in the material states that CBAM 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. Indirect emissions are taken into account only for CBAM goods where indirect emissions fall within scope.
The study is described as examining whether and how indirect-emissions coverage could be extended to additional CBAM sectors beyond current scope limits. For sectors listed in the material—aluminium including electric arc furnace steel and rolling mills; ferroalloys; cement grinding; fertilisers; hydrogen; and power-intensive processing—the direction is framed around electricity evidence becoming a competitive variable tied to claims supported by documentation.
Engineering tasks before verifier review
The material describes a gap between legal reporting steps and what is needed before verification can occur: establishing whether physical and digital plant evidence exists is characterised as an engineering task. A CBAM electricity-evidence review should examine items including a 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; and PPA settlement data.
It also lists guarantees of origin or equivalent certificate controls; production-process boundaries; electricity allocation by CN code, product route and EU export volume; reconciliation between MWh consumed and tonnes produced; and identification of evidence gaps that could force use of default values. The approach is positioned as closer to owner-engineer work than classic reporting support because it addresses whether plant architecture can support the claim used in calculations.
Metering architecture services tied to importer declarations
The service model referenced in the material describes Clarion.Engineer positioning CBAM readiness as a technical infrastructure problem built around four layers: a CBAM electrical metering architecture review; a product-level allocation model; a PPA evidence pack translated into engineering documentation; and an importer/verifier data room prepared with structured technical records.
The first layer maps physical electricity system elements behind CBAM claims including grid connection details such as substations and transformers; main meters and process meters; auxiliary loads; self-generation; direct links; PPA interfaces; and excluded loads. The output described is a “CBAM meter hierarchy” showing which meters support which production processes alongside identified evidence gaps.
The second layer develops an allocation logic model because site-level MWh alone is not sufficient under the described approach. It covers shared equipment, multiple production routes, auxiliaries, EU versus non-EU production flows, precursors and downstream processing so that allocation can be linked to production boundaries and product categories.
The third layer translates PPA arrangements into an engineering evidence package by reviewing whether PPA claims are supported by generation evidence plus metering data, settlement information, delivery periods, matching logic, certificate treatment and verifier access. The fourth layer prepares structured documentation intended for importer responsibility under CBAM declarations: it references authorisation requirements from 1 January 2026, with annual declarations due by 30 September 2027 together with certificate surrender.
This documentation set described includes a meter registry with monthly readings; SCADA extracts; PPA records; certificates; production allocation inputs; emission-factor assumptions; reconciliation checks; gap-closing actions; culminating in a verifier-facing “CBAM electricity evidence dashboard.”
