Our steel plant runs its own oxygen plant. Does its power count in our CBAM figure?
Not in the figure that is charged. An air separation unit runs on electricity, and for iron and steel only direct emissions count toward CBAM. Oxygen is not a CBAM precursor either, so oxygen bought in adds nothing. Keep the electricity data anyway: buyers' product footprints include it.
Why it drops out
Annex II of the CBAM Regulation lists iron and steel among the goods for which only direct emissions are counted. The oxygen plant's emissions come from electricity, which is indirect, so it stays outside the charged figure.
When it does count
- If the oxygen plant has its own gas or diesel generator, that fuel is a direct emission of the installation.
- For cement and fertiliser goods, indirect emissions are counted, so electricity matters there.
Why record it anyway
EU and Japanese buyers asking for a product carbon footprint want cradle to gate figures that include electricity. A separate kWh meter on the oxygen plant answers both requests from one set of records.
What Senseible does here
Senseible reads fuel, electricity and production documents into dated, fingerprinted installation records, the starting point for the actual emissions an EU importer asks for.
Sources: CBAM Regulation (EU) 2023/956, consolidated, Implementing Regulation (EU) 2023/1773, monitoring rules, European Commission, CBAM definitive regime
Last reviewed 2026-10-22.