Our plant makes the same billet in an EAF and an induction furnace. Do we report two CBAM figures?
No, one figure per CN code. EU CBAM Q&A 4.6 says that when several production routes make the same functional unit, one production process covers them all, under Article 4 of Implementing Regulation (EU) 2025/2547. Billets from your EAF and induction furnace share one embedded emissions value.
The rules that decide it
- Q&A 4.6: several production routes making one functional unit form a single production process.
- Q&A 4.7: there cannot be more than one production process per CN code in an installation.
- Q&A 4.8: you cannot split production by destination, so EU-bound heats cannot get their own figure.
- Q&A 6.6: alloy content and scrap share may vary within a CN code, but the figure is still one per CN code.
What goes into the shared figure
- Direct emissions of both furnaces: electrode carbon, charge carbon, injected coal, gas or oil for ladle and tundish preheating.
- Precursors charged in either furnace: sponge iron, pig iron and the covered ferro-alloys, FeMn, FeCr and FeNi.
- Scrap at zero embedded emissions.
- Not furnace electricity: it is not counted for iron and steel goods.
What this means commercially
If your EAF runs on more scrap and your induction furnaces on more sponge iron, every billet under that CN code carries the blended figure. You cannot quote the EAF number to an EU buyer. The lever is the mix itself: more scrap or lower carbon sponge iron in either furnace lowers the figure for all billets.
No lower figure for EU-bound heats
Q&A 4.8 also rules out splitting by destination. You cannot work out a separate figure for the lots you ship to the EU, even if they came off the cleaner furnace. Send your buyer one figure per CN code for the whole reporting period, with the tonnes it covers, and point to Q&A 4.8 if they ask for a lot-specific number.
When you do get two figures
Only when the goods fall under different CN codes, for example billets under 7207 and bars rolled from them under 7214. Embedded emissions are worked out per CN code, and the billet becomes a precursor of the bar.
Example: one year of billets under one CN code
- EAF: 60,000 t of billets, 24,000 t CO2 including precursors
- Induction furnaces: 40,000 t of billets, 70,000 t CO2 including sponge iron
- One figure: (24,000 + 70,000) / 100,000 = 0.94 t CO2 per tonne for every billet
- Not allowed: 0.40 for EAF billets and 1.75 for induction billets
Example tonnages and emissions.
What Senseible does here
Senseible reads electrode, coal, gas, sponge iron and scrap records for both furnaces into dated records and adds them into one figure per CN code. 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.
- Induction furnace billets from sponge iron
- What a verifier checks at a steel plant
- Build your CBAM file
Sources: European Commission, CBAM Questions and Answers (last updated 15 October 2026), European Commission, Guidance No. 5d, sector-specific guidance on iron and steel (14 August 2026)
Last reviewed 2026-11-01.