Cement CBAM Reporting: Avoiding the €100k Penalty on Your First Annual Submission

Short version.Cement is the highest-tonnage CBAM commodity by a wide margin — container volumes 5,000–50,000 tonnes are normal. The EU default intensity for Portland cement is high (~0.85 tCO₂e per tonne), and CBAM surrenders both direct + indirect emissions for cement during the definitive period. A 5,000-tonne shipment of Turkish Portland cement carries a CBAM cost of ~€350,000+. Miss the submission and Article 28 of Reg 2023/956 imposes the EU-ETS excess-emissions penalty (€100/t CO₂ in 2024 terms, indexed). At cement volumes, that penalty crosses six figures fast.

Cement under CBAM: the basic facts

• Scope — CN 25231000 (clinker), CN 25232100 (white Portland), CN 25232900 (other Portland), CN 25233000 (aluminous), CN 25239000 (other hydraulic). Aggregates and ready-mix concrete are out-of-scope (not in Annex I of Reg 2023/956).
• Default intensity (Portland cement)— roughly 0.85 tCO₂e per tonne, the bulk of which is the calcination of limestone (CaCO₃ → CaO + CO₂). This is irreducible chemistry; even the best cement plants can't go much lower without carbon capture.
• Surrender obligation— both direct AND indirect emissions for cement (per Reg 2025/2547). Most other sectors during the definitive period only surrender direct.
• Free allocation— cement does have an SEFA benchmark and gets a free-allocation deduction phasing out per Article 10a(1a) of Directive 2003/87/EC (97.5% in 2026, 0% by 2034).

Worked example: 5,000 t Turkish Portland cement

One containerised import of 5,000 tonnes of CN 25232900 from Turkey, imported in Q1 2026:

Numbers approximate; the actual benchmark BMg, CSCF, and rounding follow Reg 2025/2547. Run the precise calculation in the calculator.

A cement importer running 4 such shipments per quarter is carrying ~€325,000/quarter of CBAM cost. That's the number that needs to be tracked, surrendered, and audit-trailed per shipment.

The Article 28 penalty arithmetic

Article 28 of Regulation (EU) 2023/956 sets the penalty for unsurrendered emissions during the definitive period at the EU-ETS excess-emissions penalty (€100 per tonne CO₂ in 2024 terms, indexed annually per Reg 2025/2548). Plus the requirement to surrender the certificates retroactively.

Worked through the same 5,000 t cement shipment: if you fail to surrender the ~1,080 tCO₂e for that shipment by the 31 May 2027 deadline, exposure is:

• Penalty: 1,080 tCO₂e × €100 (indexed) ≈ €108,000
• Plus retroactive certificate surrender: still owe the €81,400 in certificate cost
• Total exposure: ~€189,000 for one forgotten 5,000 t shipment

For the transitional-period quarterly reports (2023–2025), the penalty range was €10–50/t indexed per Article 28. Importers who missed quarterly reports are still exposed; see our quarterly-reports checklist for the retro-fix path.

The 31 May 2027 deadline

The first annual CBAM declaration is due 31 May 2027, covering all imports made during calendar year 2026. Certificate purchase from the Registry opens 1 February 2027. That's a four-month window to:

1. Pull every CBAM-scope shipment from your customs records for 2026
2. Compute the embedded-emissions calculation per shipment
3. Aggregate at the declarant level
4. Buy certificates from the Registry covering net surrender
5. Submit the annual declaration

For cement importers running 4–8 shipments per month, that's 50–100 calculations to compile in a window already crowded with year-end accounts. Generating the per-shipment PDFs throughout 2026 (not in May 2027) is the only sustainable way.

What our calculator does for cement

• Auto-detects cement-sector CN codes (252310–252390) and applies the correct sectoral methodology.
• Surrenders both direct + indirect emissions per the cement row of Reg 2025/2547's indirect-surrender table.
• Pulls the cement-specific BMg benchmark (~0.65 tCO₂e/t) for the SEFA free-allocation deduction.
• Quick-pick deep link to common cement scenarios (Portland from Turkey, clinker from Egypt) so a broker scanning shipments can run a comparable calc in seconds.

FAQ

Sources

• Regulation (EU) 2023/956 — cement CN codes, Article 28 penalty.
• Implementing Reg (EU) 2025/2547 — cement methodology, indirect-surrender table.
• Implementing Reg (EU) 2025/2548 — certificate-price publication, Article 28 penalty indexation.