How many CBAM certificates does 100 tonnes of Portland cement need in 2026?

26, in the Commission's own worked example. 100 tonnes of Portland cement at 0.95 t clinker per tonne embeds 87.71 t CO2, direct plus indirect. The 2026 free allocation adjustment takes off 61.7 t, leaving 26 certificates, before any carbon price paid where the cement was made.

Step 1: the clinker figure

The example kiln makes 1,255,000 t of clinker a year. Raw meal calcination, coal, household waste and heavy fuel oil give 1,037,310 t CO2 of direct emissions, or 0.8265 t per tonne of clinker. Kiln electricity adds 0.0407 t per tonne as indirect emissions, which count for cement.

Step 2: carry it into the cement

• Direct: 0.8265 x 0.95 t clinker per tonne of cement = 0.7852 t CO2 per tonne
• Indirect from the clinker: 0.0387 t per tonne
• Indirect from grinding: 0.085 MWh per tonne of cement = 0.0532 t per tonne
• Total: 0.7852 direct + 0.0919 indirect = 0.8771 t CO2 per tonne of cement

Step 3: the free allocation adjustment

• Benchmark for the cement grinding process: 0
• Benchmark for grey clinker: 0.666 t CO2 per tonne, column A
• 0 + 0.95 x 0.666 = 0.6327 t per tonne of cement
• Times the 2026 CBAM factor of 97.5% and a correction factor of 1.00 = 0.617 t per tonne

What will differ for your cement

The example prices electricity at Lebanon's default grid factor, 0.626 t CO2 per MWh. Your plant uses India's default, or its own power figure if it can prove the source. Your clinker ratio moves both sides: less clinker means fewer embedded tonnes and a smaller deduction. The CBAM factor falls each year to 2034, so the same cement needs more certificates later.

What your EU buyer needs from you

Direct and indirect embedded emissions per tonne of each cement type, the clinker per tonne of cement, and a verification report. With actual data, the deduction follows your real clinker ratio. With default values, the buyer must use the default benchmarks instead.

The Commission's example: 100 t of Portland cement imported in 2026

• Direct: 100 t x 0.7852 = 78.52 t CO2
• Indirect: 100 t x 0.0919 = 9.19 t CO2
• Embedded emissions: 87.71 t CO2
• Free allocation adjustment: 100 t x 0.617 = 61.7 t CO2
• Certificates to surrender: 87.7 minus 61.7 = 26

Figures from the Commission's example installation. A carbon price paid in the country of production can reduce the number further.

What Senseible does here

Senseible turns your kiln fuel, raw meal, power and despatch records into these per tonne figures for each cement type. 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.

• Indian cement and clinker defaults
• Why the grinding benchmark is zero
• Data a grinding unit needs
• CBAM for Indian exporters

Sources: European Commission, Guidance No. 5a, sector-specific guidance on cement (14 August 2026), sections 4.1 to 4.3, European Commission, CBAM Questions and Answers (last updated 15 October 2026)

Last reviewed 2026-11-01. Re-check the CBAM factor and correction factor when the Commission updates them for 2027.