CN 2523Covered by CBAMCement

CN 2523 under CBAM — Cement & Clinker

Portland cement, aluminous cement, slag cement and similar hydraulic cements; cement clinker

Cement and cement clinker — OPC, blended cements (PPC, PSC) and the clinker they are ground from. Indian cement and clinker moves to Europe opportunistically, and coastal grinding and clinker units are the natural exporters. CBAM coverage of heading 2523 puts an embedded-emissions number on every such tonne.

Get CN 2523 CBAM handled — free Estimate my CBAM cost →

Covered

CBAM status of this heading

1 Jan 2026

Definitive phase — certificates due

€70–80

per tCO₂ — certificate price tracks EU ETS

up to ~40%

typical cost cut with verified actuals

Emission profile

Where the emissions in CN 2523 come from

Cement’s emissions are unusual: roughly 60% of the footprint comes from calcination — the chemical release of CO₂ when limestone is heated — which no fuel efficiency can remove, with kiln fuel (coal, petcoke) on top. Typical Indian OPC lands at 0.82–0.95 tCO₂/t, while blended PPC/PSC at lower clinker ratios runs 0.45–0.70 tCO₂/t. The EU default value for this heading is deliberately conservative — and blind to your clinker ratio, which is the single biggest lever a verified filing captures.

Why we don’t print a default value here

The EU publishes and updates specific default values per goods category separately — quoting a stale number would mislead you. What never changes: defaults are set deliberately high, and the markup escalates from 10% in 2026 to 30% by 2028 for steel and aluminium (free-allowance phase-out runs to 2034). Use the CBAM calculator for a current, product-specific estimate.

What to do

Exporting under CN 2523? Three moves, in order.

01
Identify your production route and precursors
Establish what you export — clinker, OPC or blended cement — and your clinker ratio, since blended cements’ lower clinker content is the dominant emissions lever. Grinding units buying clinker: that clinker is a precursor needing the kiln’s data.
02
Collect the data you already have
Kiln fuel records (coal/petcoke), limestone and raw-meal data, clinker-factor records, grinding-mill electricity bills, alternative-fuel usage logs, production data by cement type.
03
File verified actuals, not defaults
Have the numbers computed to the EU CBAM methodology and verified, then hand your EU buyer’s Authorised Declarant a filing they can use. Verified actuals typically cut the CBAM cost by up to ~40% versus default values — and the default markup only gets worse, escalating from 10% in 2026 to 30% by 2028 for steel and aluminium.

Free this quarter: We cover your first report (April–June 2026) so an inflated EU default never costs you an order. Continue only if you choose to. Free for the April–June 2026 quarter — start your report by 30 September 2026.

Start my free CBAM report

Frequently asked

CN 2523 and CBAM, in plain English

Is CN 2523 covered by CBAM?

▼

Yes. CN 2523 — Portland and other hydraulic cements, and cement clinker — is a covered good under the EU Carbon Border Adjustment Mechanism. Any consignment under this heading imported into the EU has carried reporting obligations since the transitional phase (1 October 2023 – 31 December 2025), and since the definitive phase began on 1 January 2026 the EU importer must buy CBAM certificates against its embedded emissions. Both finished cement and clinker are covered — clinker’s emissions follow it into any cement ground from it.

How much CBAM cost does CN 2523 face in 2026?

▼

CBAM certificates track the EU ETS carbon price — roughly €70–80 per tonne of CO₂ in 2026 — so the bill is your embedded emissions multiplied by that price. Cement’s embedded emissions are driven by the clinker ratio, so blended cements face materially lower bills than OPC — but only if verified actual data proves the ratio. On defaults, the EU assumes a conservative figure and your buyer overpays. Verified actuals typically cut the cost by up to ~40%.

Why can’t cement emissions just be reduced with better fuel efficiency?

▼

Because roughly 60% of cement’s CO₂ comes from calcination — the chemical decomposition of limestone into clinker — which happens regardless of how efficiently the kiln burns. Fuel choices and efficiency address the remaining share. This is why the clinker ratio is the big lever: blended cements (PPC, PSC) that substitute fly ash or slag for clinker land at 0.45–0.70 tCO₂/t versus 0.82–0.95 for typical Indian OPC — a difference a verified filing captures and a default ignores.

We grind purchased clinker at a coastal unit. Whose emissions are we filing?

▼

The clinker is a precursor — its kiln-of-origin emissions travel with it into your cement — plus your own grinding electricity. So a grinding unit’s filing combines the clinker maker’s installation data with your metered power. If the kiln operator provides verified data, your cement inherits a real number; if not, conservative defaults apply to the clinker portion, which dominates. Securing the kiln’s cooperation is the heart of the engagement.

Related CN codes