How often must we send coal, gas or limestone to a lab for EU CBAM?
The Methodology Act sets minimum analysis frequencies: natural gas at least weekly, coal and petcoke every 20,000 tonnes and at least six times a year, other fuels every 10,000 tonnes and at least four times a year, carbonate minerals every 50,000 tonnes and at least four times a year.
Minimum frequency of analyses
- Natural gas: at least weekly.
- Other gases such as process gases: at least daily, using appropriate procedures at different parts of the day.
- Fuel oils: every 20,000 tonnes and at least six times a year.
- Coal, coking coal, coke, petroleum coke and peat: every 20,000 tonnes and at least six times a year.
- Other fuels: every 10,000 tonnes and at least four times a year.
- Untreated solid waste: every 5,000 tonnes and at least four times a year.
- Liquid waste and pre-treated solid waste: every 10,000 tonnes and at least four times a year.
- Carbonate minerals including limestone and dolomite: every 50,000 tonnes and at least four times a year.
Analysis is not sampling
The table is about lab analyses. Samples or increments taken from each delivery are a separate matter, and far more than four are usually needed over a year to get a representative result.
When you may analyse less often
- The minimum would cost an unreasonable amount.
- The fuel is homogeneous, shown by data from recent reporting periods: any variation in its analytical values stays within one third of the uncertainty you apply to the activity data.
- If the table has no entry, analyse as often as keeps you at that one third level over the year.
Part-year plants and batch deliveries
Where a plant runs for part of the year, or a delivery is burnt across two reporting periods, you may choose a more suitable schedule if it gives a comparable uncertainty.
A coal-fired plant (round numbers)
- Coal burnt in a year: 500,000 tonnes.
- Minimum: one analysis every 20,000 tonnes.
- 500,000 divided by 20,000 = 25 analyses in the year, which is more than the floor of six.
What Senseible does here
Senseible reads your fuel, power and steam bills into verified emission records, so the monthly figures a monitoring plan needs are ready to hand to your verifier. Verified here means rule checks passed against the evidence. It is not third-party assurance, and a CBAM verifier still signs the report.
Sources: European Commission, CBAM Guidance No. 3, calculation of embedded emissions
Last reviewed 2026-11-04.