CBAM for cement and clinker
Because of the high emissions from burning clinker, cement is one of the core CBAM sectors. Unlike steel and aluminium, indirect emissions from electricity also count here.
At a glance
- Cement is one of the six CBAM sectors under Annex I of Regulation (EU) 2023/956.
- Counts towards the 50-tonne threshold: net mass of all CBAM goods per importer and calendar year.
- Mark-up on default values: 10% (2026), 20% (2027), 30% from 2028.
- Both direct and indirect emissions (electricity used in production) count.
Which cement goods are covered by CBAM?
What matters is the CN code in the customs declaration. The list below is Annex I as amended by Regulation (EU) 2025/2083 – the same list CBAMfix uses to check every import. You can check individual codes for free under “Check CN code”.
| CN code | Goods | Excluded |
|---|---|---|
| 2507 00 80 | Other kaolinic claysOnly calcined kaolinic clay is covered by CBAM, not uncalcined clay. | – |
| 2523 10 00 | Cement clinkers | – |
| 2523 21 00 | White Portland cement | – |
| 2523 29 00 | Other Portland cement | – |
| 2523 30 00 | Aluminous cement | – |
| 2523 90 00 | Other hydraulic cements | – |
Cement specifics
For kaolinic clay (CN 2507 00 80) only calcined clay is covered by CBAM, not uncalcined clay. The benchmarks for free allocation distinguish between grey and white clinker or cement; for clinker and hydraulic cements there are default values down to the 10-digit TARIC code.
For cement both direct and indirect emissions count – including the electricity used in production.
What does CBAM cost for these goods?
One CBAM certificate must be surrendered per tonne of embedded emissions. The free allocation adjustment that EU producers still receive is deducted – it shrinks every year (CBAM factor).
For imports in 2026 the quarterly average of EU ETS prices in the quarter of import applies: Q1: €75.36 · Q2: €75.28 · Q3: €82.32 · Q4: not yet published.
CBAM factor (share of free allocation that remains): 2026: 97.5% · 2027: 95% · 2028: 90% · 2029: 77.5% · 2030: 51.5% · 2031: 39% · 2032: 26.5% · 2033: 14% · 2034: 0%.
Without verified emission data from the producer, default values per country of origin apply, with a mark-up. Your own actual values must be confirmed by an accredited verifier – that is why it pays to ask suppliers for their data early.
Deadlines
The CBAM declaration for imports in 2026 must be submitted by 30 September 2027; the certificates must also be surrendered by then. Certificates are sold from 1 February 2027 on the common central platform. From 2027, at the end of each quarter at least 50% of the embedded emissions imported since the start of the year must be covered by certificates.
Frequently asked questions
Do indirect emissions also count for cement?
Yes. For cement and fertilisers, both direct and indirect emissions are taken into account in the definitive period.
Is clay affected?
Only calcined kaolinic clay (CN 2507 00 80). Uncalcined clay is not covered by CBAM.
Stay on top of the 50-tonne threshold
CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.
Try free for 14 daysMore topics
- Am I subject to CBAM?
- CBAM deadlines 2026 and 2027
- The CBAM annual declaration for 2026
- Which documents do I need for CBAM?
- CBAM for DDP deliveries and importers outside the EU
- The CBAM 50-tonne mass threshold
- Becoming an authorised CBAM declarant
- CBAM for customs agencies and forwarders
- CBAM certificates: price, purchase and surrender
- CBAM for electricity and hydrogen
- CBAM for iron and steel
- CBAM for aluminium
- CBAM for fertilisers
Legal status as of 11 October 2026. Based on Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 and the related implementing acts. CBAMfix does not replace legal, tax or customs advice; the Regulation and the guidance of the competent authority are authoritative.