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CN 25232900

Grey Portland cement

✓ In scope of CBAM Cement

CBAM cost preview

Live ETS price: €78.45/t CO₂. Sample: 1 tonne of CN 25232900 at default factors costs ~€10.12 in CBAM certificates today.

Direct emissions
1.24 t CO₂/t
Indirect emissions
0.05 t CO₂/t
CBAM cost (1000 t shipment)
€10,120
How is this calculated?

CBAM certificate cost = embedded emissions × ETS price × (1 − free-allocation factor) × phase-in markup.

Phase-in 2026: 10% of full certificate cost. Free allocation assumed 0% in this preview.

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Default embedded emissions

When you cannot collect verified supplier data, the EU lets you use these default values for the Cement sector.

OriginDirect emissionsIndirect emissionsTotal
Egypt1.240.051.29
India1.390.091.48
China1.350.071.42
Kazakhstan1.350.071.42
Belarus1.340.051.39

t CO₂e per tonne of product. Source: EU Implementing Reg. 2025/2621 Annex IV.

Top exporters into the EU

Eurostat Comext, latest available year. Volumes shown are extra-EU imports (tonnes).

OriginTonnes / yrShare
Türkiye1,180,00067%
Egypt410,00023%
Tunisia180,00010%

Source: Eurostat Comext annual extra-EU trade.

How to comply for this code

Methodology guide -- cement

Cement emissions come primarily from clinker calcination (CaCO3 -> CaO + CO2) -- about 60% of total. This is process emissions, not energy emissions, so switching fuel does not eliminate them.

Step 1: distinguish clinker share. A "Portland cement" with 95% clinker emits much more than a CEM II/B-V with 35% clinker + 35% fly ash. The clinker-to-cement ratio is the most material data point.

Step 2: ask about alternative fuels. Modern kilns substitute 30-60% of fuel with waste-derived fuels (RDF, biomass). This reduces direct emissions but does not affect the calcination chemistry.

Step 3: collect verified data. EU template asks for direct emissions per tonne of cement (or clinker), the clinker factor, and the kiln type (rotary, vertical shaft).

Step 4: monitor the Article 30 review. The Commission is reviewing whether to widen CBAM to downstream cement products (concrete, mortar) from 2030. Annual CN review is required.

Frequently asked questions

Is grey vs. white cement treated differently?
No -- both fall under heading 2523 with the same default direct factor (0.822 t CO2/t). White cement uses lower-iron clinker but the calcination step dominates emissions equally.
Does CBAM apply to clinker imports?
Yes. CN 25231000 (cement clinker) is explicitly in scope and typically carries the highest emissions intensity in the cement chain (about 0.83 t CO2/t direct). Importing clinker for grinding inside the EU does not avoid CBAM.
Do I have to use the EU default values?
No. Defaults are a fallback when verified supplier data is unavailable. From 2026 onward you should request actual emissions data from the producer using the EU CBAM communication template -- this is usually cheaper than using defaults, especially for low-carbon producers.
How is the cost adjusted year-on-year?
Phase-in markups apply: 10% of full certificate cost in 2026, 20% in 2027, 30% in 2028, scaling to 100% by 2034. The full calculator at /calculator applies the correct markup for your chosen year.
What about carbon prices already paid in the origin country?
Article 9 of the CBAM Regulation (EU) 2023/956 lets you deduct verifiable carbon prices paid in the country of origin. AutoCBAM Pro automates this; the free preview ignores it.

Get an emissions cost report for this product

Free PDF with sector defaults, top-3 origin countries and an ETS-linked cost forecast for CN 25232900.

Related codes

Parent heading: 2523

All codes in Cement →

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Reference data only — confirmed CBAM scope ultimately depends on TARIC declaration and the latest amendments to CBAM Annex I.