The European Commission’s technical study on indirect emissions in the Carbon Border Adjustment Mechanism (CBAM) was published through DG TAXUD on 8 June 2026. It sets out three policy questions: how operational default emission factors for indirect emissions should be determined; when declarants can claim actual indirect emissions, including via direct technical links, power purchase agreements (PPAs) and verification; and whether indirect-emissions coverage should be extended to additional CBAM sectors.
The study reframes what exporters must be able to demonstrate for CBAM declarations. Instead of treating electricity use as background consumption, it raises a physical readiness question: whether a plant’s electrical architecture can substantiate the electricity claim behind a CBAM figure.
Indirect emissions are calculated by multiplying electricity consumed during production by the applicable electricity emission factor. The Commission FAQ says the electricity emission factor may be based on the grid supplying the electricity or, where CBAM rules allow, an actual electricity emission factor. This approach creates an evidence chain that extends beyond carbon accounting and importer paperwork.
Evidence requirements for electricity used in CBAM production
To support an indirect-emissions claim, a plant must establish what electricity was consumed across installation, production process, product route, auxiliary systems and, where possible, the CBAM product category. It also needs time resolution adequate for PPA matching, onsite generation, settlement periods or verifier sampling rather than relying only on monthly data. The source of electricity must be evidenced across grid imports, onsite generation, behind-the-meter renewables, direct technical links, PPAs, supplier contracts and certificate systems.
Allocation is another technical point when plants produce multiple products, serve both EU and non-EU markets, use shared auxiliaries or operate several production routes. Verification adds further constraints because supplier statements and green certificates may not be sufficient if underlying metering, contractual and operational evidence is weak. In this context, CBAM readiness is described as requiring electrical metering architecture.
Default values under CBAM and implications for electricity claims
The definitive-period CBAM regime includes default values. The Commission’s guidance states that default values have been published and that legally binding values are set out in Commission Implementing Regulation (EU) 2025/2621. The Commission FAQ also indicates that authorised CBAM declarants may use default values for CBAM goods other than electricity when verified actual embedded-emissions data are not available.
Default values are described as country- and year-specific in the Commission FAQ. For exporters, weak electricity data can push importers toward default values rather than verified actual electricity claims. The difference between a default factor and a verified actual electricity claim can affect price, margin and market access where producers operate in carbon-intensive grids.
PPAs as a route to actual indirect emissions
The study’s second policy question focuses on actual indirect-emissions claims that can include direct technical links, PPAs and verification. It is presented as creating an opportunity for renewable developers, industrial exporters and EU buyers because a well-structured renewable PPA can become part of a CBAM value strategy rather than only an energy procurement contract.
The same material also highlights a limitation: not every green PPA will be CBAM-ready. A generic contract may support sustainability claims but does not automatically satisfy CBAM’s evidentiary requirements. Under earlier transitional-period guidance referenced in the study materials, actual electricity emission factors could be used where there is either a direct technical link between the production installation and the generation source or a PPA between consumer and producer for an equivalent amount of electricity.
A CBAM-relevant PPA is therefore expected to be engineered around evidence rather than only price. The contract should be supported by metering points, generation data, delivery shape, settlement records, guarantees of origin or equivalent certificate controls, matching methodology, balancing treatment and verifier access. The new commercial product described is “CBAM-verifiable electricity,” not simply “green electricity.”
Scope considerations for Serbia and Southeast Europe exporters
The material links the discussion to Serbia and Southeast Europe through export exposure to EU markets. It notes that exporters sell steel, aluminium, cement, fertilisers, hydrogen-related products, components or precursors into the EU market while operating across power systems with varying grid-emission intensity, renewable procurement structures and metering maturity.
The current CBAM FAQ cited in the study limits scope to direct emissions for iron/steel, aluminium and hydrogen. It states that cement, fertilisers and agglomerated iron ore must declare both direct and indirect emissions. It also says indirect emissions are taken into account only for those CBAM goods where indirect emissions fall within scope.
It also states that the Commission study examines whether and how indirect-emissions coverage could extend to additional CBAM sectors. For aluminium routes including electric arc furnace steel and rolling mills; ferroalloys; cement grinding; fertilisers; hydrogen; and other power-intensive processing categories mentioned in the material, electricity evidence is described as becoming a competitive variable.
Engineering work before verification: metering architecture review
The material describes a gap between reporting preparation and what verification requires: before a verifier can verify claims about indirect emissions from electricity use, physical and digital plant evidence must exist. It frames this as an engineering task rather than only legal or ESG reporting support. A CBAM electricity-evidence review should examine the plant single-line diagram; grid import and export interfaces; transformer and substation metering; process-level and line-level meters; SCADA/EMS systems; onsite generation metering; PPA settlement data; guarantees of origin or equivalent certificate controls; production-process boundaries; allocation by CN code with product route and EU export volume; reconciliation between MWh consumed and tonnes produced; and evidence gaps that could force default-value use.
The service model described positions Clarion.Engineer’s approach as addressing technical infrastructure needs through four layers. First is a CBAM electrical metering architecture review mapping grid connection elements such as substations, transformers, main meters and process meters alongside auxiliary loads, self-generation assets, direct links, PPA interfaces and excluded loads to produce a meter hierarchy aligned to production processes with identified evidence gaps.
Second is a product-level electricity allocation model developed for complex plants where shared equipment and multiple production routes require allocation logic across auxiliaries plus EU/non-EU production boundaries including precursors and downstream processing. Third is translation of PPAs into an engineering evidence package through review of generation evidence support, metering coverage, settlement data handling, delivery periods, matching logic, certificate treatment and verifier access to produce a CBAM-ready PPA evidence file. Fourth is preparation of an importer-facing technical data room including meter registry inputs such as monthly readings alongside SCADA extracts, PPA records, certificates, production allocation logic plus emission-factor assumptions with reconciliation checks.
Importer authorization timeline referenced in the materials
The material cites Commission FAQ requirements that EU importers must be authorised CBAM declarants from 1 January 2026. It also states that the first annual CBAM declaration for the 2026 import year is due by 30 September 2027, together with certificate surrender. It describes that this timing will increase demand for structured evidence from non-EU suppliers.
The described output from Clarion.Engineer in this layer is a verifier-facing CBAM electricity evidence dashboard. It includes meter registry information such as monthly readings plus SCADA extracts together with PPA records and certificates aligned with production allocation assumptions needed for reconciliation checks.
