Does steel or cement bought to maintain or build plant infrastructure count as a Carbon Border Adjustment Mechanism (CBAM) precursor, and can small precursor amounts be left out?

No to the first part. The Commission's Guidance No. 2 says materials bought to maintain existing infrastructure or create new infrastructure, such as steel or cement used for construction, are excluded from the installation's system boundaries. On the second part, no threshold is defined for omitting minimal amounts of precursors.

What is excluded

• The purchase and maintenance of infrastructure and equipment, as the Methodology Act (European Union (EU) Implementing Regulation 2025/2547) clarifies. Guidance No. 2 gives the example of materials bought for maintaining existing infrastructure or creating new infrastructure, such as steel or cement used for construction.
• Guidance No. 3 notes the same clarification on installation system boundaries.

What is not excluded

• A precursor is a CBAM good that is used in a production process, as defined in Article 1 of the Methodology Act.
• Guidance No. 2 says there is no threshold defined for omitting minimal amounts of precursors. Our reading: a small quantity of a listed good used in production still has to be monitored and reported.

How to keep the line clear (our reading)

• Split purchase records into two: inputs that go into a production process, and capital works or repairs.
• Write the reason for any exclusion into the monitoring plan, so a verifier can follow it.
• When one delivery serves both uses, keep the weighbridge or issue note that shows how much went where.

A re-rolling mill's year (our example)

• Billets bought for rolling: 1,200 tonnes, a precursor of the rolled product
• Structural steel bought for a new shed: 15 tonnes, excluded as infrastructure
• Precursor mass to monitor: 1,200 tonnes, not 1,215

Example numbers only. Whether a particular item is equipment or a production input is for the verifier to judge on your facts.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not decide for a verifier whether an item is infrastructure, it is not a CBAM verifier and it does not file declarations.

• Precursors bought from several suppliers
• CBAM monitoring plan checklist verifiers use
• Installation boundary with two units
• Forklifts and trucks on site
• CBAM for Indian exporters

Sources: European Commission, Guidance No. 2, Quick guide for non-EU operators on CBAM implementation, step 3 (precursors) and footnote 13, European Commission, Guidance No. 3, CBAM methods for the calculation of emissions embedded in goods (14 August 2026), table of changes from the transitional period (installation maintenance activities)

Last reviewed 2026-11-06. Wording follows Guidance No. 2 and No. 3 of August 2026. Confirm any borderline item with your verifier before the first verification.