Senseible

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

What you can still do to lower the number

Example: two lines under one CN code (example figures)

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.

Sources: European Commission, CBAM Questions and Answers (updated 15 October 2026), questions 4.4, 4.6, 4.7 and 4.8

Last reviewed 2026-11-04. Re-check questions 4.4 to 4.8 when the Commission updates the Q&A.