Emission factors from life-cycle assessments (LCA) or inventory databases are not accepted for calculating embedded emissions in the CBAM report. However, until June 30, 2024, reporting declarants may use other methods if all necessary information is unavailable. This includes using emission factors from LCA databases. Additionally, if eligible monitoring and reporting methods described in Article 4(2) of Implementing Regulation (EU) 2023/1773 utilize LCA emission factors, they may be used until the end of 2024.
While LCA databases offer comprehensive data, they often overestimate embedded emissions because the concept of embedded emissions in CBAM is narrower than the scope of LCA assessments. This discrepancy could lead to an excessive surrender of CBAM certificates, contrary to the system’s design. However, future development of CBAM-compatible datasets by LCA database providers might offer a solution, provided the datasets’ documentation ensures suitability for CBAM purposes.
Dubrink’s CBAM compliance software helps reporting declarants follow these guidelines and accurately determine embedded emissions using approved methods.