CBAM
CBAM and the Digital Product Passport
What the Carbon Border Adjustment Mechanism covers, how embedded emissions differ from a product carbon footprint, and how to run both on one data set.
The Carbon Border Adjustment Mechanism (CBAM) requires embedded emissions to be declared for certain goods imported into the EU, and the carbon cost to be equalised. It is not the same as a Digital Product Passport — but it wants the same plant data.
CBAM versus PCF
| CBAM embedded emissions | Product carbon footprint | |
|---|---|---|
| Purpose | Equalising carbon cost | Declaring environmental performance |
| Boundary | Defined processes (direct plus certain indirect) | Cradle-to-gate or cradle-to-grave |
| Method | CBAM rules | ISO 14067, PEF, GHG Protocol |
| Unit | tCO2e per tonne of product | kg CO2e per functional unit |
| Audience | Customs and authorities | Customers, consumers, the passport |
See how to calculate a PCF and ISO 14040/14044 vs 14067.
The shared data layer
Both regimes need the same underlying data:
- Site-level electricity, gas, coal and steam consumption
- Production volumes and product mix
- Process emissions (limestone calcination, for example)
- Origin and emission intensity of input materials
- Scrap or recycled input share
Building that once, per site and reportable monthly, feeds both regimes. See primary vs secondary data.
Who is affected?
CBAM goods overlap heavily with ESPR's first product groups: iron and steel and aluminium appear on both lists, so manufacturers in those sectors meet both regimes at once. See DPP for iron and steel and DPP for aluminium.
Designing the programme
- Build one data dictionary so the same field is not named differently in each regime.
- Strengthen site-level measurement: meters, production records, periodic closing.
- Resolve methodology differences in the calculation layer, not the collection layer.
- Separate the outputs: produce both the CBAM report and the passport carbon field from the same data.
Frequently asked questions
Does my CBAM report replace the carbon value in the passport?
No. Boundaries and methods differ — but the underlying plant data is shared.
What should I request from suppliers?
Emission intensity and origin of input materials. See collecting data from suppliers.
I am a small exporter. Does CBAM apply to me?
The CBAM obligation sits with the EU importer, but the data request lands on the manufacturer — exactly as with the DPP.
