# Is caustic soda exported to Europe covered by CBAM?

Canonical: https://senseible.earth/answers/is-caustic-soda-covered-by-cbam

No. Caustic soda (2815) and chlorine (2801) are not in Annex I. Hydrogen (2804 10) is, so a chlor-alkali plant selling hydrogen to an EU buyer would need a figure, though that is rare from India. Buyers may still ask for a caustic footprint.

## What buyers ask instead

Electricity per tonne of caustic by source, steam for concentration and flaking, and how emissions are shared between caustic, chlorine and hydrogen.

## India's own scheme

Named chlor-alkali plants have emission intensity targets under CCTS, which is separate from CBAM.

## What Senseible does here

Senseible reads your fuel and electricity invoices into dated, fingerprinted records, so if a buyer asks for a product footprint you can answer from documents rather than estimates.

- [Caustic soda footprint per tonne](https://senseible.earth/answers/caustic-soda-carbon-footprint-per-tonne)
- [Is my chlor-alkali plant under CCTS?](https://senseible.earth/answers/is-a-chlor-alkali-plant-covered-by-ccts)
- [Hydrogen and the 50 tonne exemption](https://senseible.earth/answers/antwerp-hydrogen-imports-cbam-50-tonne-exemption)

Sources: [CBAM Regulation (EU) 2023/956, consolidated](https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20), [European Commission, CBAM legislation and guidance](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en)

Last reviewed 2026-10-22.