Can we calculate a lower CBAM figure only for the production lots we ship to the EU?
No. Within one installation there is one production process for all goods under the same Combined Nomenclature (CN) code, so you cannot work out embedded emissions for EU-bound lots on their own. The Commission says production cannot be split artificially by destination. One CN code gets one figure.
What the Commission says
The Commission's Carbon Border Adjustment Mechanism (CBAM) Questions and Answers answer this in two short steps. Question 4.7: there cannot be more than one production process per CN code, because Article 4 of Implementing Regulation (EU) 2025/2547 requires a production process to be identified for all goods under the same functional unit, for example the same CN code.
Question 4.8 goes straight at your case: you cannot artificially split production processes based on their destination. EU-bound and non-EU lots under one CN code share one figure.
What this means on your shop floor
- Two lines making the same CN code, one old and one new: one figure covers both, weighted by what each made.
- A batch made with cleaner fuel for one EU buyer: its fuel is part of the whole process, not a separate figure.
- Several routes into one product: question 4.6 says one production process covers all the routes.
- For iron and steel, CN codes that differ only in size or shape and use the same precursors in the same types, quantities and proportions must be grouped into one process (question 4.4), so you cannot split those to flatter one of them.
What you can still do to lower the number
- Report actual verified emissions instead of the default value, which carries a mark-up.
- Cut real emissions on the line: fuel, power and process emissions all feed the one figure.
- Keep clean, dated records so a verifier can accept your actual figure.
Example: two lines under one CN code (example figures)
- Line A, newer: 6,000 t at 1.80 t CO2e per tonne = 10,800 t CO2e
- Line B, older: 4,000 t at 2.40 t CO2e per tonne = 9,600 t CO2e
- One process: (10,800 + 9,600) / 10,000 t = 2.04 t CO2e per tonne
- Your EU buyer takes 3,000 t, all from line A. The tempting figure is 1.80. The figure allowed is 2.04
Example numbers only. CO2e means carbon dioxide equivalent.
What Senseible does here
Senseible reads fuel, power and material invoices per site into one dated record, so the whole-installation total behind your single figure is easy to show. The CBAM suite builds the verifier-ready file from them and every figure is checked in-house; an accredited verifier Senseible partners with signs it off, or you send it to your own.
Last reviewed 2026-11-04. Re-check questions 4.4 to 4.8 when the Commission updates the Q&A.