Are our own lime kiln and coke ovens inside the CBAM boundary of our steel products?
No. EU CBAM Q&A 6.4 says lime kilns and coke oven plants are outside the system boundaries for iron and steel production, because lime and coke are not CBAM goods. Their fuel and calcination stay out, and lime and coke enter your steel figure as inputs with no embedded emissions.
What stays out of the steel figure
- Fuel burnt in your lime or dolomite kilns, and the CO2 released when limestone is calcined there.
- Coal heating and losses in the coke oven battery.
- Any embedded emissions for the lime and coke themselves. Neither is a precursor, so neither carries a figure into your steel.
What still counts
- Coke, coal and other reducing agents burnt in the blast furnace or sinter strand: their carbon is a direct emission of your iron making.
- Coke oven gas, blast furnace gas or converter gas burnt in a process inside the steel boundary.
- Raw limestone or dolomite charged straight into the sinter strand, blast furnace or converter. That calcination happens inside your boundary.
Records the verifier will want
- Meters on coke oven gas going to steel units, so the gas burnt inside the boundary is counted and the rest is not.
- Quicklime and calcined dolomite issued to the shops, kept apart from raw flux charged.
- A carbon mass balance across coke, coal, scrap, steel and slag.
Your own footprint is different
Outside CBAM, a buyer asking for a full product footprint will still expect the kiln and coke oven emissions. Keep them on record; they simply do not belong in the CBAM figure.
Example: what goes into one year's CBAM figure
- Own lime kiln: coal and calcination CO2 left out
- Quicklime to the converter: 150,000 t, counted at zero
- Raw dolomite charged to the sinter strand: 40,000 t at 95% purity
- Dolomite CO2: 40,000 x 0.95 x 0.477 = 18,126 t CO2, counted in sinter direct emissions
Example tonnages. 0.477 t CO2 per tonne is the stoichiometric factor for pure dolomite.
What Senseible does here
Senseible reads coal, coke, flux and gas records into dated records per unit, so kiln and coke oven inputs can be kept apart from what counts. 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.
Sources: European Commission, CBAM Questions and Answers (last updated 15 October 2026), European Commission, Guidance No. 5d, sector-specific guidance on iron and steel (14 August 2026)
Last reviewed 2026-11-01.