Southeast European cement and fertiliser producers may face CBAM exposure linked to materials manufactured outside their own facilities. For cement grinding plants and fertiliser blending businesses, upstream emissions can outweigh those from local processing. As a result, supplier information and sourcing choices for EU customers are central to the emissions picture.
Both sectors rely on upstream inputs, but their emissions calculations use different production boundaries and monitoring requirements. Cement assessments must cover clinker, finished-product composition and processing activities. Fertiliser calculations depend on chemical precursors, nitrogen content and the specific manufacturing route. The guidance also notes that a generic method used for steel or aluminium would not capture these sector-specific requirements.
Cement reporting depends on clinker sourcing and product composition
The European Commission’s sector guidance highlights the role of clinker in cement calculations based on composition. A grinding plant purchasing clinker must identify the source, obtain the applicable emissions information, and include emissions from its own processing activities. Clinker content is described as a key parameter in cement emissions reporting and procurement.
When a grinding business considers changing the clinker share, it must assess the potential emissions effect alongside product composition, strength requirements and customer specifications. The guidance states that reducing the clinker ratio can offer advantages only if the resulting cement remains suitable for its intended use and alternative constituents are reliably available. It also cautions against basing commercial claims solely on lower calculated carbon intensity without confirming technical suitability.
Material traceability is identified as another requirement for defensible calculations. A plant may receive clinker from multiple production installations, store it, and allocate it across different cement products. The calculation needs to connect sources, quantities consumed and resulting output within the relevant reporting period, rather than relying on annual purchase totals alone.
The document describes a verification challenge for grinding businesses when upstream documentation is difficult to obtain. Records for local electricity and fuel consumption may be readily available, while upstream clinker emissions reports can be harder to secure. The risk is said to be higher when purchases are made through traders instead of directly from producing installations.
Supply agreements are expected to address availability of evidence needed for reporting. Any change in clinker source should trigger a review of both documentation and technical quality requirements. The guidance also frames the most useful comparison for exporters as complete supply routes that combine technical acceptability with documentation supporting emissions calculations.
Fertiliser calculations rely on precursor routes and nitrogen-related inputs
Fertiliser manufacturers face different upstream dependencies than cement operators. The Commission’s guidance identifies chemical precursors such as ammonia and addresses indirect electricity emissions where applicable. For nitric acid production, it specifies monitoring of nitrous oxide (N₂O) using the relevant measurement approach.
The production route must be mapped before operators can determine what information is required for the calculation. A fertiliser blending facility may have relatively limited emissions at its own site while depending on several upstream production records. Management is expected to identify covered inputs and determine how their quantities and relevant characteristics contribute to the finished product’s calculated emissions.
The guidance notes that supplier sustainability reports may provide background but may not include product-specific or installation-specific evidence needed for calculations. It also emphasizes that product composition affects how emissions figures are communicated to customers. Comparisons between fertilisers should use consistent product definitions and applicable units, since figures expressed per tonne of commercial product should not be compared indiscriminately with values based on different functional units or compositions.
Manufacturers are expected to state clearly what each reported intensity represents and maintain that definition across documentation and customer communications. This includes ensuring that reported intensities remain consistent when used in customer-facing materials tied to regulatory reporting needs.
Electricity treatment differs from direct-emissions-only approaches
The guidance distinguishes electricity’s role from a direct-emissions-only treatment applicable to Annex II metal goods. Cement and fertiliser producers are instructed to examine electricity consumption together with relevant calculation factors under rules governing their products. For electricity procurement arrangements, businesses considering renewable supply are told to verify whether arrangements satisfy applicable requirements for the intended emissions treatment.
A general claim that electricity is renewable is described as insufficient on its own to establish results under the relevant methodology. Electricity procurement is also linked with precursor sourcing in how emissions contributions are assessed together. A cement plant may improve its electricity supply while remaining heavily exposed to a high-emissions clinker source, while a fertiliser blender may reduce energy use locally even if purchased-chemical emissions dominate its product calculation.
Investment decisions should compare contributions from each emission source to identify where reductions are most feasible. Upstream improvements are described as potentially offering the greatest impact even when local energy-efficiency measures remain financially worthwhile under business constraints.
Stock management, logistics costs and evidence gaps affect CBAM readiness
Seasonal procurement and stock management can influence how reliable emissions records are during reporting periods. Producers may buy materials ahead of expected demand or keep buffer inventories to protect against supply interruptions. Reporting teams must distinguish between quantities purchased in a period and quantities actually consumed in production.
The distinction supports more reliable calculations and helps explain differences between cash purchasing expenditure and material costs attributed to current production. Transport, storage and financing costs are also described as factors when comparing alternative suppliers, because switching clinker or ammonia sources can change freight expenditure, warehousing requirements and working-capital needs even when those costs do not fall within the embedded-emissions boundary used for CBAM calculations.
The guidance states that commercial sourcing models should remain consistent with regulatory calculations while keeping a clear separation between financial costs and emissions included under CBAM rules. It also notes that efficient grinding or blending operations cannot replace missing production data for received materials when documentation is required for emissions calculations.
Controls focus on critical inputs rather than broad automation
For smaller cement and fertiliser producers, the guidance suggests starting with a limited set of critical inputs instead of investing immediately in extensive automation. It points to tools such as a precursor register, a supplier documentation schedule, and reconciliation of consumption against production to identify information gaps most likely to matter for calculations.
Additional meters and monitoring controls should be prioritised where they improve reliability of parameters required by applicable calculations. Investment should respond to defined monitoring needs rather than simply increasing installed equipment capacity.
The document also distinguishes between changes in reported emissions intensity and changes in final CBAM certificate requirements. It states that certificate calculation methods and adjustments need separate assessment because a percentage reduction in reported intensity does not necessarily translate into an equivalent percentage reduction in final cost. It further notes that EU customers may value lower reported intensity for commercial or environmental reasons, but financing decisions should be based on expected cost effects under applicable rules rather than assumed proportionality.