CBAM Calculation Methodology

1. Emission Calculation

CbamTrack follows the methodology set out in Commission Implementing Regulation (EU) 2025/2621. Emissions are calculated per product using the formula:

• Direct emissions — calculated from natural gas, diesel, coal, and fuel oil consumption using standard emission factors from IR (EU) 2025/2621 Annex II.
• Indirect emissions — calculated from electricity consumption multiplied by the country-specific grid emission factor.
• Per-ton reporting — total emissions divided by the total exported tons of the product.

2. Electricity Grid Factors

Country-specific electricity grid emission factors are sourced from IR (EU) 2025/2621 Annex III and supplemented by national grid operator data where available.

When a country-specific factor is not available, the default factor (0.451) is used with a 10% markup as required by IR (EU) 2025/2621 Art. 5. Affected calculations are clearly marked in the UI.

3. De Minimis Exemption

Per IR (EU) 2025/2621 Art. 2, companies with total production below 50 tons per quarter are exempt from CBAM reporting requirements. CbamTrack automatically detects this condition and displays a warning when generating reports for de minimis quantities.

4. ETS Carbon Price

The EU ETS carbon price is used to estimate CBAM liability. CbamTrack uses a 3-tier fallback chain:

1. Manual override — via ETS_PRICE_OVERRIDE environment variable.
2. Database price — official administered ETS price stored in the database.
3. Hardcoded fallback — €75.36/tCO₂e (Q2 2026 reference).

The active price source is displayed as a badge (Manual, Official, or Fallback) on all cost estimates.

5. Anomaly Detection

CbamTrack analyzes emission data for anomalies using sector-specific benchmarks and energy consistency checks. Detected anomalies are flagged in reports with contextual warnings. This is a pattern-based analysis, not AI-based — all rules are deterministic and auditable.

6. Audit Trail

All data changes (product creation, emission updates, report generation) are logged with user identity, timestamp, and before/after values. The audit log is accessible from the dashboard and provides a complete history for compliance verification.