Which chemicals made in Cilegon fall under EU CBAM?
Only a few. Hydrogen (2804 10 00), ammonia (2814), nitric acid (2808) and nitrogen fertilisers (3102 and 3105) are CBAM goods. Polymers, methanol, chlor-alkali products and other petrochemicals are not in Annex I, so exporting them to the EU needs no CBAM figure today.
Covered
- 2804 10 00: hydrogen, direct emissions only.
- 2814: ammonia.
- 2808: nitric acid.
- 3102 and 3105: nitrogenous and mixed fertilisers, with indirect emissions included.
Not covered
- Chapter 39 plastics in primary forms, such as polyethylene and PVC.
- 2905 alcohols, including methanol.
- 2815 caustic soda and 2801 chlorine.
What buyers still ask
EU buyers of uncovered chemicals may still want a product carbon footprint for their own Scope 3 reporting. Keep fuel, steam and electricity records by plant so one can be built.
What Senseible does here
Senseible reads the energy invoices behind the making stage into a fingerprinted Scope 1 and 2 record, and keeps material invoices on the Scope 3 trail. Material factors come from your supplier or a named database and are labelled with their source, so the product figure can be traced line by line.
Sources: Regulation (EU) 2023/956 (CBAM Regulation), consolidated, European Commission, CBAM definitive regime
Last reviewed 2026-10-21.