Final Report

Technical study on indirect emissions in the CBAM - Final Report

The study “Technical Study on Indirect Emissions in the CBAM” analyses how indirect emissions can be calculated, reported and potentially extended under the Carbon Border Adjustment Mechanism (CBAM). Indirect emissions are defined as emissions from electricity generation consumed during the production of CBAM goods. The report was commissioned by the European Commission in preparation for the definitive CBAM period from 2026 and focuses on methodological, legal and practical design questions.

The report addresses three main questions: 

  1. how to determine default emission factors for indirect emissions in third countries (Task 1); 
  2. under which conditions actual indirect emissions may be claimed (Task 2); and 
  3. whether, and how, indirect emissions coverage could be extended to further CBAM goods and sectors (Task 3). 

The analysis combines methodological assessment, review of current CBAM rules, scenario testing and structured input from stakeholders and experts.

The study finds that different approaches to default emission factors involve different trade-offs. For claims based on actual indirect emissions, physical connectivity, smart metering, traceable electricity flows, clear contractual arrangements and verifiable evidence are identified as key requirements. For a possible extension of indirect emissions coverage to further CBAM goods, the study highlights trade-offs between environmental integrity, carbon leakage prevention, administrative feasibility and even-handed treatment of EU producers and importers. Phased or compensation-linked approaches are described as relatively feasible options.