Senseible

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

What goes into the shared figure

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

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.

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.