Which parts of a cement plant are inside the European Union (EU) Carbon Border Adjustment Mechanism (CBAM) boundary, from the raw mill to the bagging plant?

The Commission's cement guide puts inside the boundary raw material grinding, fuel preparation, the kiln and cooler, clinker storage under cover, cement grinding, storage, packaging, dispatch and emissions control. Equipment unrelated to cement production, and the purchase and upkeep of infrastructure and equipment, are outside.

A conveyor belt from rock to bag

A cement plant is one long belt: crush and grind the raw mix, burn it into clinker, grind clinker with additives into cement, bag it. CBAM is the EU's charge on the carbon built into imported goods. The guide says which stretches of that belt belong to the figure.

Clinker side, inside the boundary

• Raw material preparation: grinding, milling and homogenisation.
• Fuel storage and preparation, for conventional and waste-derived fuels.
• Clinker burning: the whole kiln system, including preheating, kiln processing and clinker cooling.
• Intermediate storage of clinker under cover before it is exported or ground.
• Emissions control for releases to air, water or ground.

Cement side, inside the boundary

• Handling and pre-treatment of clinker, calcined clay and mineral additives, for example pre-heating and drying the additives.
• Cement production: crushing, grinding, further milling and separation by particle size.
• Cement storage, packaging and dispatch.
• Emissions control.

Outside

• Emissions from the purchase and maintenance of infrastructure and equipment.
• Other industrial equipment unrelated to cement production. The guide says to exclude it from the system boundaries.
• The guide's list starts at raw material preparation. It does not name quarrying or limestone crushing at the mine, so ask your verifier where it puts that line.

Electricity is inside

Cement is not on the list where only direct emissions count, so electricity used by the kiln system and the cement mill is reported separately and counted, with their direct emissions.

Electricity by area at one plant in a year (example)

• Raw mill and kiln: 62,000 megawatt hours. Cement mill: 41,000. Packing plant: 3,500. Township and guest house: 1,800
• Inside the boundary: 62,000 + 41,000 + 3,500 = 106,500 megawatt hours
• Left out as unrelated to cement production (our reading): 1,800, which is 1.7% of the plant total
• Keep a sub-meter for each area so the line can be shown to a verifier

Meter readings are example numbers. Whether a given load is unrelated to cement production is for your verifier to confirm.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Sub-metering your plant is custom, on request, so until then the split by area comes from your own meters. Senseible builds the verifier-ready file and checks every figure in-house; an accredited verifier Senseible partners with signs it off, or the client sends it to their own.

• Build your cement CBAM file
• Verifier checks at a cement plant
• Forklifts, trucks and loaders on site
• Why cement CBAM is per tonne of clinker content
• Cement grinding unit benchmark of zero

Sources: European Commission, CBAM Guidance No. 5a, cement (14 August 2026)

Last reviewed 2026-11-07. Check sections 2.2.3 and 3.2 of the guide against Annex I, points 3.3 and 3.4 of Implementing Regulation (EU) 2025/2547. The guide says it is not legally binding.