Cement Importers & CBAM: Calculation Methods & Deadlines

Cement and clinker are among the most carbon-intensive CBAM-covered products. This guide covers everything cement importers need for compliant quarterly CBAM reporting.

CN Codes for Cement Products

Cement products fall under HS Chapter 25, primarily within the 2507 and 2523 ranges:

Product Type	CN Code	Description
Kaolin	2507	Kaolin and other kaolinic clays
Clinker	2523 10	Cement clinkers
White Portland	2523 21	White Portland cement
Other Portland	2523 29	Other Portland cement
Aluminous	2523 30	Aluminous cement
Other hydraulic	2523 90	Other hydraulic cements

Each CN code carries specific default emission factors. Using the wrong code results in incorrect calculations and potential compliance issues.

Emission Factors for Cement

Cement production is inherently carbon-intensive due to the calcination process:

Product	Default Factor (tCO₂e/tonne)	Key Source
Clinker	0.92	Calcination + fuel
Portland cement	0.87	Clinker dilution
White Portland	0.88	Selective raw materials
Aluminous cement	0.95	Higher alumina content
Other hydraulic	0.85	Varies by formulation

The clinker-to-cement ratio is the primary driver of emission intensity. Higher clinker ratios mean higher embedded emissions.

Country-Specific Factors

Cement emission factors vary significantly by country due to different energy mixes and production efficiencies:

Country	Direct Factor Range	Notes
Turkey	0.61–0.72	Mixed fuel sources
China	0.82–0.95	Coal-heavy production
India	0.75–0.88	Varies by plant
Egypt	0.70–0.82	Natural gas dominant
Vietnam	0.68–0.80	Improving efficiency

Always use country-specific default factors rather than global averages for accurate reporting.

Data Collection for Cement Imports

Required Data Points

• Specific CN code (not just "cement")
• Quantity imported (tonnes)
• Clinker ratio (if known)
• Country of origin
• Supplier-specific data (if available)

Documentation to Maintain

• Mill certificates with clinker content
• Supplier emission declarations
• Import customs declarations
• Bill of lading

CbamTrack provides pre-configured cement product templates with correct CN codes and emission factors.

Common Cement-Specific Errors

Using generic "cement" — Different cement types (Portland, aluminous, hydraulic) have different CN codes and factors. Always specify the exact product type.

Ignoring clinker ratio — The clinker-to-cement ratio directly affects embedded emissions. If your supplier provides this data, use it for more accurate calculations.

Wrong country factors — Cement production in coal-heavy economies (China, India) has higher emissions than gas-based production (Egypt, parts of Turkey).

FAQ

Do I need to report for cement clinker separately from finished cement? Yes. Clinker (CN 2523 10) and finished cement (CN 2523 29) are different CN codes with different emission factors.

What if I don't know the exact cement type? Use the most specific CN code available. If you only know it's "Portland cement," use 2523 29 rather than the general 2523 code.

Can I use actual emission data instead of defaults? Yes. If your supplier provides verified emission data, you can use actual factors. This typically results in lower reported emissions for efficient producers.

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CbamTrack automates cement CBAM reporting with pre-configured CN codes, country-specific emission factors, and quarterly report generation. Start free to streamline your cement import compliance.