Can we use emission factors from an LCA database for our CBAM figure?
No. The EU's CBAM Q&A 4.24 says emission factors from life-cycle assessments or life-cycle inventory databases are not accepted for the embedded emissions of CBAM goods. Use the standard factors in the CBAM monitoring rules for fuels and materials, and verified data or EU default values for precursors.
What will be refused
- A cradle-to-gate factor for bought billet, rod or coil taken from an LCA database.
- A product footprint figure from an EPD used as a precursor's embedded emissions.
- Database factors for coal, coke or natural gas that include mining, processing and transport before the fuel reaches you.
What to use instead
- Fuels and process materials: the standard factors in Annex II, section G of Implementing Regulation (EU) 2025/2547, such as 56.1 t CO2 per TJ for natural gas with a net calorific value of 48 GJ per tonne, as the Commission's iron and steel guidance uses.
- Precursors: the supplier's verified embedded emissions, or the EU default values in Implementing Regulation (EU) 2025/2621.
- Electricity, where it counts: the country default factor published by the Commission, or an actual factor where the rules allow it.
Why LCA factors do not fit
They fold in upstream steps that CBAM boundaries leave out, and they describe an average product, not your installation. CBAM wants the emissions of your process and your actual precursors.
Example: natural gas in a forging shop, one year
- Gas burnt: 2,000 t
- Energy: 2,000 t x 48 GJ per tonne = 96,000 GJ, or 96 TJ
- Emissions: 96 TJ x 56.1 t CO2 per TJ = 5,385.6 t CO2
Example quantity. Standard factors as used in the Commission's iron and steel guidance.
What Senseible does here
Senseible works out fuel emissions from the quantities on your invoices with IPCC-based factors, not LCA database values. 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 4.24, European Commission, CBAM Guidance No. 5d, iron and steel (14 August 2026), sections 3 and 4.2, Implementing Regulation (EU) 2025/2621, default values
Last reviewed 2026-11-01.