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Requirement · CALC-01

Count the embedded emissions of Annex VIII input materials (precursors) when determining the embedded emissions of the goods.

Operators and authorised CBAM declarants calculating embedded emissions must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

  • It is Art. 1(6)(a), inserting Art. 7(2a) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
  • The act gives its timing as: applies from 1 January 2028 per Art. 2. as of 2026-08-14
  • It names 2 industries by name: Steel and Aluminium. as of 2026-08-14
  • Compliance is checked by accredited third party, annual. as of 2026-08-14
Addressee Operators and authorised CBAM declarants calculating embedded emissionsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(6)(a), inserting Art. 7(2a) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

production of CBAM goods using input materials listed in the new Annex VIII

Obligation

Count the embedded emissions of Annex VIII input materials (precursors) when determining the embedded emissions of the goods.

Who is affected

Addressee
Operators and authorised CBAM declarants calculating embedded emissions
Class
Businesses
Sectors
Names Steel, Aluminium and metals
Applies
applies from 1 January 2028 per Art. 2

Burden drivers

D4 · D2 — 2 of 7 marks fire on this provision.

Source text

Verbatim

‘2a. Embedded emissions in input materials (precursors) listed in Annex VIII shall be considered in the determination of embedded emissions in goods.

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