Which tonnes count as production in a UK CBAM figure?
Saleable tonnes. HMRC's guidance defines activity level as the total tonnes of goods produced under the CN codes of the aggregated goods category, including product used as a precursor in your own next process. Product returned to the same process, waste and scrap are excluded.
Count
- Saleable goods under the relevant CN codes, added together for the aggregated goods category.
- Product transferred directly into another of your production processes as a precursor.
Do not count
- Product returned to the same process, such as re-melted crop ends.
- Waste and scrap.
Why it moves your figure
Intensity is emissions divided by tonnes. Counting scrap or recirculated material as output makes the figure look lower than it is, which a verifier will find and correct.
Worked example: a rolling mill
- Direct and precursor emissions for the year: 52,800 tCO2e.
- Bars rolled: 24,600 t. Crop ends and miss-rolls re-melted: 1,400 t.
- Activity level: 24,600 minus 1,400 = 23,200 t.
- Intensity: 52,800 / 23,200 = 2.27586 tCO2e per tonne. Counting all 24,600 t would wrongly give 2.14634.
What Senseible does here
Senseible keeps production and dispatch quantities by product next to fuel and power, so the divisor and the emissions come from the same period. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
Sources: HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)
Last reviewed 2026-11-02.