CBAM Reporting Requirements for Indian Steel and Cement Exporters

Key Takeaways

• Quarterly Deadlines: Reports due 1 month after quarter end (Jan 31, Apr 30, Jul 31, Oct 31).
• Mandatory Fields: Installation ID, Production Process, Direct Emissions, Indirect Emissions, Precursor Emissions.
• Granularity: Data must be reported at the installation level, not company level.

Introduction

Standard customs documentation is no longer sufficient for exporting Steel (CN 72/73) or Cement (CN 25) to the EU. The CBAM Transitional Registry requires specific, granular data. For Indian exporters, missing a single field in the "CBAM Communication Template" often leads to the EU importer rejecting the shipment data.

The CBAM Data Structure

The report is not a simple PDF; it is structured data (XML/Excel). Key components include:

1. Installation Data

• Name & Address: Physical location of the factory (Mumbai, Gujarat, Odisha, etc.).
• Coordinates: Latitude/Longitude (to verify location).
• UNLOCODE: Nearest port code.

2. Production Process Parameters

• Production Route: E.g., "Electric Arc Furnace" vs "Basic Oxygen Furnace".
• System Boundaries: Defining what processes are included (e.g., "Coke making -> Sintering -> Blast Furnace").
• Activity Level: Net production in tonnes.

3. Emissions Data

• Specific Direct Emissions: $tCO2e / t_{product}$ (Scope 1).
• Specific Indirect Emissions: $tCO2e / t_{product}$ (Scope 2).
• Precursor Emissions: The embedded emissions of input materials (e.g., clinker for cement, pig iron for steel).

2025-2026 Regulatory Impact for India

• Strict Validation: The EU Commission's registry now performs automated checks. "Zero" emissions or "Default" values are increasingly flagged for manual review.
• Correction Window: You maintain the right to correct reports for 2 months after submission. Use this window to refine data if initial estimates were rough.

Specific Guidance for Cement

• Clinker Factor: The ratio of clinker to cement is the biggest driver. Reducing clinker (using Fly Ash/Slag) allows Indian exporters to report significantly lower numbers.
• Kiln Fuel: Usage of Alternative Fuels (AFR) needs to be documented carefully to claim lower emission factors.

Specific Guidance for Steel

• Scrap vs Sponge Iron: India uses a high proportion of Sponge Iron (DRI-Coal), which has a high carbon footprint. Accurately measuring the coal consumption in the DRI kiln is critical.
• Rolling Mills: If you are a re-roller, 90% of your carbon footprint comes from the steel billet you bought. You must get the CBAM data from your billet supplier.