Senseible

How is the free allocation adjustment worked out when I use actual CBAM data?

For each process, specific free allocation equals the CBAM factor times the cross-sectoral correction factor times the process benchmark. A simple good takes that figure. A complex good adds, for each bought or own precursor, its mass per tonne times that precursor's own figure. EU-made precursors count as zero.

Step 1: the process figure

SFA = CBAM factor x CSCF x BM*. The CBAM factor is 97.5% for 2026, 95% for 2027 and 90% for 2028. BM* is the process-related benchmark from column A of the Free Allocation Adjustment Act, the same for every country. The year is the year the good was produced.

Step 2: simple good

No precursors, so the specific embedded free allocation (SEFA) equals the process figure.

Step 3: complex good

SEFA = process figure + sum of (mass of precursor i per tonne of good x SEFA of precursor i). Mass per tonne is the total precursor mass used in the process divided by the tonnes of good made in it. Repeat down the chain until a precursor has no precursors.

Which precursor values

About the correction factor

The guidance table shows 1.0 for every year and calls those values preliminary. Its footnote says the 2026 to 2030 values are in Implementing Decision (EU) 2026/1862, so check that decision for the final figure.

Who uses the result

The importer deducts SEFA times the tonnes imported from the embedded emissions to get the CBAM obligation. As operator you supply SEFA in the verified emissions report.

What Senseible does here

Senseible reads your production and purchase documents into quantities by product, which feeds the mass figures. The benchmark look-up and the calculation are done in the Commission's template.

Sources: European Commission, CBAM Guidance No. 4, free allocation adjustment (14 August 2026), section 2.2.1, equations 1 to 5, and Table 2-1

Last reviewed 2026-10-25.