Do kiln start-up oil and raw material dryer fuel count in a cement plant's CBAM figure?
Yes. Every fuel burnt inside the installation for making clinker and cement counts as a direct emission, including oil or diesel used to light up the kiln after a stop and fuel for raw material or coal dryers. Leaving them out understates the figure and fails a verifier's completeness check.
Fuels to list
- Main kiln and calciner fuels: coal, pet coke, alternative fuels.
- Start-up fuel: light diesel oil, furnace oil or HSD.
- Dryer and hot gas generator fuel.
- Diesel for mobile equipment inside the boundary, if your method includes it.
How to record
Take quantities from stock and issue registers, not only from purchase invoices, and convert with the fuel's net calorific value and factor.
Small but checked
Start-up fuel is a small share, but verifiers compare fuel registers with purchases. A missing line looks like a control gap.
What Senseible does here
Senseible reads fuel, power and production records into dated, fingerprinted installation records, the starting point for the actual emissions your EU importer asks for.
Sources: Implementing Regulation (EU) 2023/1773, CBAM reporting rules, 2006 IPCC Guidelines, Volume 2: Energy, CBAM Regulation (EU) 2023/956, consolidated
Last reviewed 2026-10-22.