Cement manufacturers in the Western Balkans can reduce reported embedded emissions by using qualifying renewable electricity arrangements under the European Union Carbon Border Adjustment Mechanism (CBAM). The current definitive CBAM methodology includes indirect electricity-related emissions for covered cement goods, unlike most covered steel and aluminium products.
This approach places electricity procurement in the regulatory emissions calculation. The outcome depends on eligible generation data, contractual arrangements, and reliable allocation of electricity consumption to individual cement products.
The largest emissions components in cement manufacturing are linked to clinker production, calcination and thermal energy consumption. Renewable electricity can improve the reported carbon intensity of covered products, but it does not replace measures targeting direct process emissions and kiln fuel consumption.
For export-oriented producers, the investment challenge is to combine electricity-related improvements with clinker and process decarbonisation while maintaining evidence that supports the applicable CBAM methodology.
Clinker, calcination and electricity use different emission controls
Cement manufacturing involves multiple production stages with distinct energy requirements and emissions characteristics. Calcination during clinker production generates substantial direct carbon dioxide emissions through chemical transformation of raw materials.
Thermal energy used in kiln operations is another major component of sector carbon intensity. Electricity consumption is associated with grinding, conveying, fans, mills and shared utility systems.
Because these processes contribute differently to the reported emissions result, manufacturers need to distinguish between clinker, individual cement types and other relevant production outputs. The monitoring system should connect electricity consumption to applicable production stages and allocate shared energy use consistently.
Reliable production volumes and clinker-to-cement ratios are also needed. Changes in product composition can affect embedded emissions intensity even when overall site energy consumption remains relatively stable.
Qualifying renewable electricity requires CBAM-aligned measurements
Covered cement products can benefit from lower eligible electricity emissions factors when manufacturers meet requirements under the applicable CBAM methodology. Potential arrangements include on-site solar photovoltaic generation, direct technical connections and qualifying physical power purchase agreements (PPAs).
Generation and consumption measurements must be preserved at required time intervals. The generating installation must provide verified emissions information.
The structure of electricity procurement agreements therefore matters for regulatory reporting. A conventional annual purchase of renewable electricity certificates may support other corporate renewable energy claims but should not automatically be treated as sufficient evidence for an actual-value electricity calculation under CBAM.
The industrial buyer must identify which electricity quantities meet the methodology’s conditions rather than relying only on an annual renewable procurement percentage.
Grid imports and renewable shortfalls need separate MRV treatment
A cement factory operating under a long-term renewable electricity contract may still consume substantial quantities of grid electricity. Generation shortfalls, interruptions or periods when renewable output does not match industrial demand can require additional electricity purchases.
The monitoring, reporting and verification (MRV) system should distinguish qualifying renewable electricity consumption from volumes requiring applicable fallback emissions treatment. Applying a single renewable electricity factor to total annual consumption may not reflect the actual eligibility of the electricity used.
Separating these quantities allows management to evaluate how additional qualifying renewable supply could improve the reported indirect emissions component. It also provides a basis for assessing whether further procurement, storage or operating adjustments would deliver sufficient value relative to their cost.
Efficiency measures and operating schedules affect renewable coverage
Renewable electricity procurement should be coordinated with industrial energy-efficiency measures. Grinding optimisation, high-efficiency electric drives, improved fan controls and preventive maintenance can reduce electricity consumption per tonne of cement.
Lower energy demand can reduce operating costs while decreasing the quantity of renewable electricity needed to cover factory consumption. Where production schedules allow, selected electricity-intensive processes may be operated during periods with greater renewable availability.
Cement plants with multiple grinding mills or production lines can examine differences in energy efficiency and allocate production accordingly. Using a more efficient mill during periods of abundant renewable generation may improve both electricity costs and the indirect emissions component if product quality and operating requirements are maintained.
Such changes should be evaluated using actual production data rather than assumptions about performance of individual manufacturing lines.
Cement product mix changes embedded emissions without changing power demand
Cement producers need to evaluate energy performance alongside finished product composition. A product with a lower proportion of clinker may show lower embedded emissions because its direct process-emissions contribution is reduced.
However, producing that cement may require additional grinding, potentially increasing electricity consumption per tonne. A single energy-intensity indicator could therefore suggest deteriorating efficiency even when overall product emissions improve.
Management should assess electricity consumption together with clinker content, production route, process emissions and finished product quantities. The same principle applies when allocating electricity between quarry operations, clinker manufacturing and cement production.
Where the applicable CBAM reporting boundary requires these activities to be distinguished, site-wide renewable electricity percentages may not adequately represent the electricity associated with individual covered products.
Verification depends on complete installation-level evidence
A lower electricity emissions factor cannot compensate for missing or unreliable information about clinker production and direct industrial emissions. A verification-ready monitoring system needs raw-material records, kiln emissions, fuel consumption, measurable heat where relevant, electricity measurements and manufacturing output.
These records must support calculation of embedded emissions under appropriate product and production boundaries. Electricity data should form part of a wider installation-level evidence system rather than operate as a separate renewable energy reporting exercise.
This enables independent reviewers to examine how direct process emissions, precursor or material information, thermal energy and qualifying electricity consumption contribute to the final reported result.
Decarbonisation investment comparisons use verified reductions per tonne
Cement producers can compare decarbonisation investments based on expected cost and emissions reductions recognised under the applicable methodology. Potential measures include renewable electricity procurement, alternative kiln fuels, clinker substitution, waste heat recovery and industrial process-efficiency improvements.
These options can differ in capital expenditure, implementation requirements and potential emissions impact. Renewable electricity may address a smaller share of total footprint than measures reducing clinker-related emissions but can be quicker to implement and easier to verify.
A combined marginal abatement cost assessment allows management to compare costs for achieving a verified tonne of emission reduction through different investments. This can support phased programmes that introduce electricity-related improvements while larger process-decarbonisation projects are developed.
Electricity evidence links CBAM performance with financing assessments
The inclusion of eligible indirect electricity emissions in CBAM creates a connection between qualifying renewable arrangements and regulatory emissions performance for cement manufacturers. For lenders assessing solar photovoltaic investment or physical PPAs, manufacturers can demonstrate how electricity measurements and supporting generator information enter product-level emissions calculations.
The financial appraisal must also determine whether resulting carbon-related value is captured by the exporter or initially benefits the EU importer. A reduction in the importer’s potential CBAM certificate obligation does not automatically become additional revenue for the cement producer.
Banks are expected to examine commercial arrangements through which any carbon-related benefit is recognised alongside contractual reliability of the electricity evidence. Financing assessments can distinguish between direct electricity-cost savings, recognised emissions improvements and additional customer value supported by contractual commitments.
Customer carbon footprint calculations may use similar controlled data
Verified electricity information can also support cement manufacturers responding to customer reporting beyond CBAM. European industrial buyers may request broader product carbon footprint calculations incorporating electricity consumption alongside other production-related emissions.
The same controlled electricity measurements, generation records and procurement documentation can provide source information where relevant methodology permits their use. Treatment of electricity, production boundaries and applicable emissions factors may differ between CBAM and broader product-footprint frameworks.
Maintaining one reliable evidence base while preparing separate methodology-specific calculations allows exporters to support customs-related reporting, commercial product declarations and corporate sustainability disclosures without assuming resulting carbon figures must be identical.

