// regulation → measurement

CBAM
Carbon border adjustment: actual, verified emissions instead of defaults

From 2026 the CBAM price is paid on embedded emissions. Default values are expensive; measured, verified emissions are the lever — and measurement-based monitoring means continuous CO₂ measurement in the flue gas.

EU importers of cement, iron & steel, aluminium, fertilisers, hydrogen, electricityNon-EU producers supplying the EUVerifiers
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Key dates
1 Oct 2023
Transitional period: quarterly reports, no payment (Art. 36(2))
31 Dec 2024
Authorisation of declarants opens (Art. 5, 10, 14, 16, 17)
1 Jan 2026
Definitive period: authorised declarants, certificates, verified emissions (Art. 36(2)(b))
What the rule requires

Article references are to the text in the Official Journal; summaries are informational, not legal advice.

Scope — Annex IGoods by CN code: cement, electricity, fertilisers, iron and steel, aluminium, hydrogen — with the greenhouse gases listed per product (CO₂; N₂O for nitric acid; PFCs for aluminium).
Embedded emissions — Art. 7 & Annex IVDeclared per installation on actual emissions where available; default values otherwise (with mark-ups).
Monitoring methods — Impl. Reg. 2023/1773 Annex III BCalculation-based (standard or mass-balance) or measurement-based: 'continuous measurement of the concentration of the relevant greenhouse gas in the flue gas and of the flue gas flow'. The most accurate and reliable method must be chosen.
Verification — Art. 8Emissions declarations verified by an accredited verifier; measurement records and calibration evidence are part of the audit trail.
What you have to measure
  • CO₂ concentration in the flue gas (continuous) + flow → mass emissions, for the measurement-based method
  • N₂O in nitric-acid plant tail gas (fertilisers)
  • CF₄ / C₂F₆ in aluminium smelter exhaust (anode effects)
  • Process CO₂ in hydrogen and cement kilns
// Default values carry a mark-up and rise over time; declarations without verification are not accepted; penalties for non-surrender of certificates follow the ETS excess-emissions penalty logic (Art. 26).
Tremon products for this rule
Questions engineers ask
Does a non-EU plant need EU-certified analyzers?
The Implementing Regulation asks for a monitoring methodology plan with the most accurate reliable method and verification; traceable calibration records are what verifiers check. Certification schemes are not prescribed.
Can the same analyzer serve IED and CBAM?
Often yes: a continuous CO₂ channel with QAL3-style drift control provides both the permit data and the CBAM measurement-based data.
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Three taps and an email. An engineer replies within 24 h with feasibility and a price indication.

1 · Which gas?
2 · What for?
3 · What form?
4 · Where do we reply?
Goes to sales@tremon.nl. No newsletter, no tracking.
Other regulations
Sources
  1. Regulation (EU) 2023/956, OJ L 130, 16.5.2023 — Art. 7, 8, 26, 36, Annex I, Annex IV; text saved 2026-09-17
  2. Implementing Regulation (EU) 2023/1773, OJ L 228, 15.9.2023 — Annex III section B (monitoring methodologies); text saved 2026-09-17
// Read from the Official Journal texts on 2026-09-17. Regulations change — verify the current consolidated text before acting.
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