# Our melt shop does not lab-test every lot. Which carbon figures does the EU let us use instead under CBAM? Canonical: https://senseible.earth/answers/cbam-standard-values-type-one-and-type-two You may use a fixed carbon figure instead of a lab test if your monitoring plan names it. The guide sorts fixed figures into Type II, which is more accurate, and Type I, which applies only where no Type II figure exists for the same material. Small streams suit fixed figures. For the largest streams the guide recommends lab analysis. ## What a fixed figure is Every fuel or material you burn or melt has a carbon figure. The guide calls it a calculation factor. You can send a sample to a lab to get it, or you can use a fixed figure someone else already published. It is like reading the fat content off a food label instead of testing the food yourself. The guide says calculation factors are often set to fixed values because they give sufficiently representative data on average over a whole reporting system. It also says the factor must match the state of the tonnes you weighed. If the tonnes are as taken from the pile, with rain on them, the carbon figure must be for the same moisture level. ## Type II: the list the guide rates more accurate - Standard factors the country where the plant stands used for its latest national inventory submission to the United Nations Framework Convention on Climate Change (UNFCCC). - Values published by national research institutions, public authorities, standardisation bodies or statistical offices for more disaggregated reporting. The guide's own example is a research institute publishing different coal factors for different mines or regions. - Values specified and guaranteed by the supplier, where there is evidence that the carbon content exhibits a 95% confidence interval of not more than 1%. - Stoichiometric values for the carbon content of a pure substance, with literature values for its net calorific value (NCV). - Values from lab analyses carried out in the past, not older than two years and considered representative for the fuel or material. ## Type I: the fallback list The guide says Type I values apply only if no Type II value is available for the same parameter and material or fuel. My reading: if India's latest national inventory has a factor for your exact fuel, look there before you reach for an IPCC table value. - Standard factors in point G of Annex II to the Methodology Act. The guide copies them into its Annex D. (The Methodology Act is the Commission's implementing rule for how embedded emissions are worked out.) - Standard factors in the latest guidelines of the Intergovernmental Panel on Climate Change (IPCC). - Values from lab analyses carried out in the past, not older than five years and considered representative for the fuel or material. ## Where fixed figures sit on the ladder The guide lists these with increasing data quality. The first ones are meant for rather small source streams. For the largest emissions the guide recommends the best type of analysis. It is a recommendation, not a requirement. 1. Fixed values, Type I. 2. Fixed values, Type II. 3. Correlations for determining proxy data. 4. Lab analyses outside your control, for example by the fuel supplier, in purchase documents, with no information on the methods. 5. Lab analyses in non-accredited labs, or in accredited labs with simplified sampling. 6. Lab analyses in accredited labs applying best practice on sampling. ## What to write in the plan Lay down in the monitoring plan which values you use, so the figures cannot change without a reason. The guide says the verifier uses the plan to check your method, so the values you rely on belong in it. ## Example: a Type I figure turned into carbon dioxide (CO2) - Fuel: 50 tonnes of diesel (example). Annex D, Table 4-7, gas/diesel oil: 74.1 tonnes of CO2 per terajoule (TJ), net calorific value 43.0 TJ per gigagram (1 gigagram = 1,000 tonnes). - Energy: 50 / 1,000 x 43.0 = 2.15 TJ - CO2: 2.15 x 74.1 = 159.3 tonnes, about 3.19 tonnes of CO2 per tonne of diesel Figures are from the guide's own table. If a Type II factor exists for your diesel, it comes first. ## 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. - [How often coal, gas or limestone must go to a lab](https://senseible.earth/answers/cbam-eu-fuel-analysis-frequency-table) - [Coal as received or air dried: which basis](https://senseible.earth/answers/coal-as-received-vs-air-dried-basis) - [Update the monitoring plan after a plant change](https://senseible.earth/answers/cbam-monitoring-plan-update-after-plant-change) - [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 (calculation factors, Type I and Type II lists) and Annex D, Table 4-7, dated 14 August 2026. The list of six methods and the 'increasing data quality' note are the guide's own words. The sentence about looking for a national factor first is marked as my reading of the 'only if no Type II value is available' rule. The 159.3 tonnes line was checked again: 2.15 x 74.1 = 159.3. The guide is the Commission's explanation, not the legal text. The Commission may revise its guidance, so check the current version.