# Our coal supplier prints a carbon and heat value on the invoice. Does the EU accept it for the Carbon Border Adjustment Mechanism (CBAM)?

Canonical: https://senseible.earth/answers/cbam-coal-supplier-carbon-figure-on-invoice

The EU guide allows it. A lab result printed in the purchase documents is the fourth of six methods, above fixed values. A guaranteed value counts as Type II only with evidence of a 95% confidence interval of not more than 1%; without it, Type I, the lowest rung. The figure must be an actual lab analysis of that delivery.

## Three ways a supplier figure can arrive

1. The supplier prints an actual lab result of that delivery in the purchase documents, with no information on the method. The guide lists this as a method for setting calculation factors: lab analyses carried out outside the operator's control, for example by the supplier.
2. The supplier specifies and guarantees the value, and there is evidence that the carbon content exhibits a 95% confidence interval of not more than 1%. The guide calls this a Type II standard value.
3. The supplier guarantees a value but that variation level is not met. Footnote 43 says the value would then be considered a Type I value.

## What the confidence interval means in plain words

My reading: the guide does not define it further. In plain terms it asks the supplier to show that the carbon content stays within a narrow band. Ask for the records behind the guarantee, not just the promise. The guide says only 'evidence'. What counts is for your verifier to decide.

## What a supplier figure does not do

- It does not replace your tonnes. The guide says official information such as invoices may be used for the quantity of fuels and materials, but the carbon figure and the tonnes are two separate numbers.
- It must match the state of the tonnes you weighed. My reading: a dry-basis carbon figure applied to wet coal overstates the carbon per tonne, so check which basis the supplier used.
- It does not stay in the plan by itself. The guide says you must lay down in the monitoring plan which values you use.

## Example: one invoice figure used in the carbon balance

- Lot: 300 tonnes of coal. Supplier printed carbon content 0.61 tonnes of carbon per tonne (example).
- Carbon in: 300 x 0.61 = 183 tonnes of carbon
- Carbon dioxide (CO2): 3.664 x 183 = 670.5 tonnes of CO2 (3.664 is the ratio of the molar masses of CO2 and carbon, printed in the guide's Equation 12)

Example figures. Equation 12 in the guide is Em = f x AD x CC, where AD is the tonnes and CC the carbon content.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into dated, fingerprinted records. It does not run lab tests, write a monitoring plan or verify a CBAM figure.

- [Standard values, Type I and Type II](https://senseible.earth/answers/cbam-standard-values-type-one-and-type-two)
- [One lab result covers only its own lot](https://senseible.earth/answers/cbam-one-coal-lab-result-covers-only-its-own-lot)
- [Coal as received or air dried: which basis](https://senseible.earth/answers/coal-as-received-vs-air-dried-basis)
- [CBAM readiness for exporters](https://senseible.earth/cbam)

Sources: [European Commission, CBAM Guidance No. 3, methods for calculating embedded emissions (14 August 2026)](https://taxation-customs.ec.europa.eu/document/download/29b9eec7-1a4b-4eb6-ab85-96a0c9e35fd0_en?filename=Guidance%20No.%203%20-%20CBAM%20methods%20for%20the%20calculation%20of%20emissions%20embedded%20in%20goods.pdf)

Last reviewed 2026-11-07. Facts are from Guidance No. 3, section 4.6.1.4, the list of six methods, the Type II bullet on supplier guarantees and footnote 43, and Equation 12 in section 4.6.1.2, dated 14 August 2026. The plain-words reading (marked 'My reading' on the page) of the confidence interval, and the advice to ask for records, are mine; the guide says only 'evidence'. The example sum was checked again: 300 x 0.61 = 183, 183 x 3.664 = 670.5.