The European Commission’s technical study on indirect emissions in the Carbon Border Adjustment Mechanism (CBAM), published through DG TAXUD on 8 June 2026, sets out three policy questions. These cover how operational default emission factors for indirect emissions should be determined, when declarants may claim actual indirect emissions, and whether indirect-emissions coverage could extend to additional CBAM sectors.
The study shifts the compliance focus for exporters from documentation to physical readiness. The central readiness question becomes whether a plant’s electrical architecture can support the electricity claim behind the CBAM number.
In this context, electricity is treated as a compliance object rather than background consumption. The Commission’s work places electricity consumed in producing CBAM goods, the emissions factor applied to that electricity, and the evidence needed for low-carbon claims into the same compliance frame as other emission sources.
Indirect emissions calculation and evidence requirements
Indirect emissions are calculated by multiplying electricity consumed during production by the applicable electricity emission factor. The Commission FAQ indicates that the electricity emission factor may be based on the grid supplying the electricity or, where permitted by CBAM rules, on an actual electricity emission factor.
The calculation depends on an evidence chain that extends beyond site-level totals. A plant must be able to identify what electricity was consumed across installation, production process, product route, auxiliary systems, and where possible, CBAM product category.
Time resolution is also part of the evidence requirement. Monthly data may not be sufficient when PPA matching, onsite generation settlement periods, or verifier sampling require stronger time granularity.
Evidence must also address electricity origin. Grid import, onsite generation, behind-the-meter renewable assets, direct technical links, PPAs, supplier contracts, and certificate systems can each trigger different evidence needs under CBAM rules.
Allocation methods become a technical risk point in multi-product operations. When a plant produces multiple products, serves both EU and non-EU markets, uses shared auxiliaries, or operates several production routes, electricity allocation requires documented logic.
Verification readiness depends on more than statements. Supplier statements and green certificates may not be sufficient if metering records and contractual or operational evidence are weak.
Default values under CBAM and exporter risk
The definitive-period CBAM regime includes default values for certain inputs. The Commission’s CBAM legislation and guidance page states that default values have been published and that legally binding values are set out in Commission Implementing Regulation (EU) 2025/2621.
The Commission FAQ also explains that authorised CBAM declarants may use default values for CBAM goods other than electricity where verified actual embedded-emissions data are not available. It further states that default values are country- and year-specific.
For exporters, weak electricity data can affect how importers complete declarations. If importer calculations rely on defaults due to insufficient electricity evidence, the difference between a default factor and a verified actual electricity claim can have commercial implications for price, margin, and market access.
Actual indirect emissions claims through links and PPAs
The study’s second policy question focuses on when declarants may claim actual indirect emissions. This includes claims supported by direct technical links, PPAs, and verification processes.
The framework creates an opportunity for renewable developers, industrial exporters, and EU buyers seeking to support actual indirect-emissions claims. A structured renewable PPA can function as more than energy procurement if it is supported by CBAM-relevant evidence.
At the same time, not all “green” PPAs meet CBAM requirements. A generic contract may support sustainability messaging outside CBAM, but CBAM requires stronger evidentiary logic tied to how actual electricity emission factors are justified.
Under earlier transitional-period default-values guidance referenced in the study context, actual electricity emission factors were allowed where there is either a direct technical link between the production installation and the electricity generation source or a PPA between consumer and producer for an equivalent amount of electricity.
A CBAM-relevant PPA therefore needs contractual support aligned with metering and settlement evidence. The contract should be backed by metering points and generation data, delivery shape and settlement records, guarantees of origin or equivalent certificate controls, matching methodology and balancing treatment, plus verifier access arrangements.
Scope considerations for Serbia and Southeast Europe
The study’s implications are relevant for Serbia and Southeast Europe due to regional export patterns into the EU market. Exporters in these markets sell steel, aluminium, cement, fertilisers, hydrogen-related products, components and precursors into the EU.
Regional industrial operations also face different power-system conditions. The grid-emission intensity of local systems varies alongside renewable procurement structures and metering maturity levels across countries in Southeast Europe.
The current CBAM FAQ states that scope is limited to direct emissions for iron/steel, aluminium and hydrogen. It also states that cement, fertilisers and agglomerated iron ore must declare both direct and indirect emissions.
The FAQ further indicates that indirect emissions are taken into account only for CBAM goods where indirect emissions fall within scope. The Commission’s study nonetheless examines whether indirect-emissions coverage could extend to additional CBAM sectors beyond those currently specified.
Engineering tasks before verification
Companies often approach CBAM through legal reporting channels such as tax or customs processes alongside ESG reporting. The study context highlights that this is necessary but incomplete because verification depends on whether physical and digital plant evidence exists.
A CBAM electricity-evidence review should examine multiple technical elements within a facility. These include the plant single-line diagram; grid import and export interfaces; transformer and substation metering; process-level and line-level meters; SCADA/EMS systems; meter-data systems; onsite generation metering; PPA settlement data; guarantees of origin or equivalent certificate controls; production-process boundaries; and how electricity allocation is handled by CN code, product route and EU export volume.
The review also includes reconciliation between MWh consumed and tonnes produced. It should identify evidence gaps that could force reliance on default-value approaches for indirect-emissions calculations.
Metering architecture review model for exporter readiness
The service model described positions CBAM readiness as a technical infrastructure issue tied to electrical metering capability. It is structured around four layers covering metering architecture assessment through importer-facing evidence preparation.
The first layer is a CBAM electrical metering architecture review. It maps grid connection details including substations and transformers; main meters; process meters; auxiliary loads; self-generation; direct links; PPA interfaces; excluded loads; and produces a meter hierarchy showing which meters support which production processes alongside identified evidence gaps.
The second layer develops a product-level allocation model rather than relying only on site-level MWh totals. It addresses shared equipment arrangements; multiple production routes; auxiliaries; EU versus non-EU production; precursors; downstream processing; resulting in an allocation logic model intended for review by importers, auditors and verifiers.
The third layer converts PPA documentation into an engineering evidence pack aligned with CBAM requirements. It reviews whether PPA claims are supported by generation evidence together with metering records, settlement data, delivery periods, matching logic, certificate treatment approaches and verification access arrangements.
The fourth layer prepares an importer-usable data room for verification workflows. The Commission FAQ states that importers must be authorised CBAM declarants from 1 January 2026, with the first annual declaration for the 2026 import year due by 30 September 2027, together with certificate surrender.
This data room includes items such as meter registry entries; monthly readings; SCADA extracts; PPA records; certificates; production allocation outputs; emission-factor assumptions; reconciliation checks; plus gap-closing actions. The output is described as a verifier-facing dashboard covering CBAM electricity evidence inputs used in indirect-emissions calculations.