Why is the CBAM benchmark for cement grinding zero?

Because grinding clinker into cement usually releases no direct emissions, the CBAM benchmark for the cement production process is 0. The free allocation deduction on cement comes only from the clinker inside it: 0.666 t CO2 per tonne of grey clinker, times the clinker per tonne of cement.

Where the zero comes from

The Commission's cement guidance explains it in one line: in most installations no direct emissions occur when cement is made from clinker, so the benchmark of the cement production process is zero, while the clinker benchmark carries the weight. The values sit in column A of the annex to Implementing Regulation (EU) 2025/2620.

How the deduction is built

1. Take the cement benchmark: 0.
2. Add the clinker per tonne of cement times the grey clinker benchmark, 0.666.
3. Multiply by the year's CBAM factor (97.5% in 2026) and the correction factor (1.00 in the guidance's 2026 example).

What it means for a grinding unit

• Your mill electricity and any dryer fuel add to the embedded emissions of your cement. They add nothing to the deduction.
• Less clinker per tonne lowers both your embedded emissions and the deduction. As long as your clinker carries more CO2 per tonne than the deduction gives back, 0.666 x 0.975 = 0.649 t in 2026, less clinker still means fewer certificates.
• Grey and white clinker take different benchmarks, marked (A) and (B). Make sure each cement type is reported against the right one.

The number your buyer cannot do without

The clinker per tonne of cement, for each cement type, from your own production records. It sets the deduction, so a verifier will check it against clinker received, stock and despatches. Send it with your direct and indirect figures per tonne.

Example: deduction per tonne in 2026, OPC against PPC

• OPC at 0.95 t clinker per tonne: 0 + 0.95 x 0.666 = 0.6327, x 0.975 = 0.617 t CO2
• PPC at 0.65 t clinker per tonne: 0 + 0.65 x 0.666 = 0.4329, x 0.975 = 0.422 t CO2
• Grinding power adds to embedded emissions in both cases, and to neither deduction

The OPC line is the Commission's own example. The PPC clinker ratio is an example; use your measured figure.

What Senseible does here

Senseible keeps clinker receipts, power bills and despatch records as dated records, so the clinker ratio and grinding emissions per cement type come straight from documents. We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them.

• Certificates for 100 t of cement
• Data a grinding unit needs
• CBAM benchmark values
• CBAM for Indian exporters

Sources: European Commission, Guidance No. 5a, sector-specific guidance on cement (14 August 2026), sections 4.1 to 4.3, European Commission, CBAM Questions and Answers (last updated 15 October 2026)

Last reviewed 2026-11-01.