Do diesel forklifts and trucks inside our plant count in our CBAM embedded emissions?
No. The EU's CBAM Q&A 4.21 excludes emissions from mobile machinery such as trucks and forklifts, the same rule as the EU ETS. Transport on conveyor belts, in pipelines or by other stationary equipment is included. Leave forklift diesel out of the CBAM figure, but keep it in your Scope 1.
In or out
- Out: forklifts, internal trucks, dumpers and loaders moving material around the site.
- In: conveyor belts, pipelines and other stationary equipment that moves material. Where these burn fuel, that fuel counts. Where they run on electricity, it counts only for goods whose indirect emissions are declared, such as cement and fertilisers.
- For steel, aluminium and hydrogen only direct emissions count, so an electric conveyor adds nothing there.
Keep the diesel apart
If one tank feeds a generator or burner and the forklifts, keep the issue register by equipment. Without it, the verifier cannot see which litres you left out.
Where forklift diesel still belongs
Your company footprint, BRSR answers and buyer questionnaires count fuel burnt in your own vehicles as Scope 1. Only the CBAM figure leaves it out.
Example: a re-rolling mill, one month
- Furnace oil in the reheating furnace: 12,000 L x 2.97 kg = 35,640 kg CO2, counted for CBAM
- Diesel in two forklifts: 900 L x 2.645 kg = 2,380.5 kg CO2, left out of CBAM
- Scope 1 for the month: 35,640 + 2,380.5 = 38,020.5 kg CO2
Example quantities. Factors used: 2.97 kg CO2 per litre of furnace oil and 2.645 per litre of diesel.
What Senseible does here
Senseible reads fuel invoices and slips line by line, so diesel bought for forklifts stays apart from the fuel your furnace burns. 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 (15 October 2026), question 4.16 and 4.21
Last reviewed 2026-11-01.