CBAM for Cement Exporters
Carbon Border Adjustment Mechanism (CBAM) compliance for exporters of cement and clinker to the European Union, worldwide, and for the EU importers who declare them. Embedded emissions calculated from installation data, CBAM reports prepared for verification by accredited verifiers, and certificate exposure estimated and managed, as one accountable engagement delivered from Mumbai.
Reviewed by Team GreenSutra · Updated 20 July 2026
What CBAM means for cement exporters
Cement trades regionally, and the largest CBAM exposed suppliers sit around the Mediterranean.
The Carbon Border Adjustment Mechanism (CBAM) prices the carbon emissions embedded in imported goods, and cement is one of the six covered product groups, covering clinker and finished cement. The European Union imported about 11.3 million tonnes of cement and clinker in 2024, so the definitive regime, which has applied since 1 January 2026, reprices market access for the major supplier countries.
Because cement is heavy and low in value, it trades regionally: Türkiye supplies around two fifths of EU imports, North Africa a further third, and Ukraine much of the rest, while India is a negligible supplier since its cement ships to nearer markets. GreenSutra works as a CBAM consultant for cement exporters and the EU importers and authorised declarants who file for them.
Exposure tracks the clinker content and the country of origin. The table below shows the leading suppliers of cement to the EU and how CBAM bears on each.
| Market | Share of EU imports, 2024 | CBAM exposure |
|---|---|---|
| Türkiye | Around 39 percent, the largest supplier | The most exposed by volume, on a higher carbon thermal energy mix. |
| Ukraine | Around 14.5 percent | A significant clinker and cement supplier, exposure set by the specific plant. |
| Algeria | Around 14 percent | Modern kilns; efficient plants sit below the default estimate on verified data. |
| Egypt | Around 9 percent | Gas fired kilns, exposure set by the clinker carbon intensity. |
| Tunisia | Around 8 percent | North African supply, exposure set by the specific installation. |
| India | Negligible | Cement ships to nearer markets, so India has near zero direct EU cement exposure. |
Import volumes from Eurostat and Cement Europe, 2024. Cement counts both direct and indirect emissions, and clinker carries the bulk of them, so the clinker content of a product drives its exposure. The CBAM cost of any specific plant turns on its clinker carbon intensity and verified emissions, so the figures above frame exposure rather than fix a bill. A first step is the structured CBAM discovery brief, after which exposure feeds the CBAM cost calculator. The full deadlines and methods are set out in the CBAM compliance guide.
Cement products and their default values
The India default embedded-emissions values that apply where verified data is not supplied.
Coverage follows the combined nomenclature (CN) code of each good, from clinker through grey and white Portland cement to aluminous cement. The India defaults below count direct and indirect emissions, and each carries a mark-up of 10 percent in 2026, 20 in 2027 and 30 from 2028.
The representative values below span the cement range. Each is a single country-of-origin default; the figure for a specific product turns on its clinker content and, where supplied, the plant verified emissions.
Reading down the table, the grey and white Portland cements cluster near 1.45 tonnes of CO2e per tonne, while aluminous cement sits well above at 2.29. Because cement ships in high volume and the definitive regime prices both direct and indirect emissions, even that spread moves a certificate position at scale, before verified plant data is brought in.
| Product | Representative CN | India default (tCO2e/t) |
|---|---|---|
| Grey cement clinker | CN 2523 10 00 | 1.44 |
| Grey Portland cement | CN 2523 29 00 | 1.48 |
| White cement clinker | CN 2523 10 00 | 1.41 |
| Aluminous cement | CN 2523 30 00 | 2.29 |
Values are the India totals of direct and indirect emissions, specific to the country of origin, so the set differs elsewhere. Source: Implementing Regulation (EU) 2025/2621, Annex I. Clinker carries most of the embedded carbon, so a cement with a lower clinker factor carries less. Estimate a specific product, volume and route in the CBAM cost calculator.
How a cement CBAM engagement runs
From exposure assessment to a prepared, declared and managed certificate position.
Assess CBAM exposure
Cement and clinker products, CN classification, clinker content, export destinations and volumes mapped against the definitive regime, the de minimis threshold and the authorised declarant requirement.
Calculate embedded emissions
Direct and indirect embedded emissions of each product quantified from actual installation and clinker data following the EU methodology, in place of default values that carry a mark-up, then prepared for verification.
Prepare for accredited verification
Installation data and the monitoring methodology behind it prepared for confirmation by an accredited verifier, so the declared embedded emissions stand on evidence rather than marked up default values.
Report through the CBAM registry
Verified data shared with EU importers and authorised declarants through the central CBAM registry, and the annual declaration prepared so every covered consignment is accounted for.
Manage CBAM exposure and reduce
Certificate exposure tracked against the EU ETS price, any carbon price paid at origin deducted, and a reduction pathway built to lower the clinker factor and the cost over time.
How CBAM works for cement
The border mechanism follows the embedded emissions of cement or clinker from the kiln across the European border to the certificate that is surrendered.
A kiln produces clinker, the emission heavy intermediate, from which cement is ground. Most of the embedded carbon comes from the chemical calcination of limestone and the fuel burned in the kiln.
Both direct process and fuel emissions and indirect, electricity related emissions are counted for cement, measured from installation data or estimated with a country and product specific default value that carries a mark-up.
An accredited verifier confirms the actual data, which is shared with the European importer through the central CBAM registry.
The good crosses the European border, where an authorised CBAM declarant reports the embedded emissions for the year above the 50 tonne de minimis.
CBAM certificates are surrendered for the embedded emissions, priced off the EU ETS, with any carbon price already paid at origin deducted.
Direct and indirect embedded emissions are measured at the kiln, verified and shared through the CBAM registry, then declared at the European border by an authorised declarant who surrenders certificates priced off the EU ETS. Cement counts both direct and indirect emissions, and clinker carries the bulk of them. First surrender, covering 2026 imports, falls on 30 September 2027.
Embedded emissions follow each cement product from the kiln to the European border, and a readiness review turns that path into a measured, verified compliance plan.
WhatsAppRequest a CBAM readiness review →What CBAM readiness earns a cement exporter
The gains of moving from marked up default values to verified installation data.
Market access retained
Verified embedded emissions data keeps cement and clinker moving into the European market under the definitive regime without compliance friction.
Lower certificate cost
Actual verified data replaces the conservative default, so the certificate obligation reflects the real clinker factor and kiln rather than a penalty estimate.
Trusted supplier status
Sharing verified data through the CBAM registry positions the plant as a preferred supplier to European importers and declarants.
Decarbonisation advantage
A lower clinker factor and cleaner kiln lower embedded emissions over time, an advantage that grows as the payable share climbs toward 100 percent in 2034.
CBAM for cement exporters, answered
Q·01Which cement products does CBAM cover?
Q·02What are the CBAM default values for cement?
Q·03Does CBAM count indirect, electricity emissions for cement?
Q·04Which countries are most affected, and where does India sit?
Q·05How much will CBAM cost cement exporters?
Q·06Does verified data really lower the CBAM cost for cement?
Q·07Who verifies the emissions data, and can a verifier in India do it?
Request a CBAM readiness review for cement
A short conversation about cement and clinker products, clinker content, export volumes and the European buyers involved turns into a tailored CBAM plan. Schedule a call directly or send a written brief.
Pick the service and a slot; a practitioner takes the call.
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Maintained by GreenSutra · Last reviewed July 2026