# Do kiln start-up oil and raw material dryer fuel count in a cement plant's CBAM figure?

Canonical: https://senseible.earth/answers/cbam-cement-kiln-startup-oil-counted

Yes. Every fuel burnt inside the installation for making clinker and cement counts as a direct emission, including oil or diesel used to light up the kiln after a stop and fuel for raw material or coal dryers. Leaving them out understates the figure and fails a verifier's completeness check.

## Fuels to list

- Main kiln and calciner fuels: coal, pet coke, alternative fuels.
- Start-up fuel: light diesel oil, furnace oil or HSD.
- Dryer and hot gas generator fuel.
- Diesel for mobile equipment inside the boundary, if your method includes it.

## How to record

Take quantities from stock and issue registers, not only from purchase invoices, and convert with the fuel's net calorific value and factor.

## Small but checked

Start-up fuel is a small share, but verifiers compare fuel registers with purchases. A missing line looks like a control gap.

## What Senseible does here

Senseible reads fuel, power and production records into dated, fingerprinted installation records, the starting point for the actual emissions your EU importer asks for.

- [Ariyalur fuel mix](https://senseible.earth/answers/ariyalur-cement-plant-fuel-mix-co2)
- [Diesel issue register](https://senseible.earth/answers/own-diesel-tank-issue-register-emissions)
- [CBAM installation boundary](https://senseible.earth/answers/cbam-installation-boundary-two-units)

Sources: [Implementing Regulation (EU) 2023/1773, CBAM reporting rules](https://eur-lex.europa.eu/eli/reg_impl/2023/1773/oj/eng), [2006 IPCC Guidelines, Volume 2: Energy](https://www.ipcc-nggip.iges.or.jp/public/2006gl/vol2.html), [CBAM Regulation (EU) 2023/956, consolidated](https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20)

Last reviewed 2026-10-22.