Reference · steel-v1

CBAM Steel Data Dictionary

Every field we collect to calculate embedded emissions for steel, what a verifier expects behind it, and the rule that requires it. Validation, the readiness score, the anomaly thresholds and the entry forms are all generated from this table rather than restating it, so a rule change moves in one place.

Steel only. Other sectors run through the same Annex IV engine but do not yet have a dictionary, and we would rather say that than imply coverage we have not written.

Methodologies in force

  • CBAM-2026.1 — 2026-01-01 to 2027-12-31

    • Reg. (EU) 2023/956 — CBAM Regulation, Annex IV
    • IR (EU) 2025/2547 — calculation methods for embedded emissions
    • IR (EU) 2018/2066 — EU ETS monitoring and reporting, applied by reference
    • IR (EU) 2025/2621 — default values
    • IR (EU) 2025/2620 — free allocation adjustment
    • IR (EU) 2025/2546 — verification
    • Reg. (EU) 2025/2083 — amending Reg. (EU) 2023/956
    • Del. Reg. (EU) 2025/2551 — accreditation of verifiers

  • CBAM-2028.1 — 2028-01-01 to open

    • Reg. (EU) 2023/956 — CBAM Regulation, Annex IV
    • IR (EU) 2025/2547 — calculation methods for embedded emissions
    • IR (EU) 2018/2066 — EU ETS monitoring and reporting, applied by reference
    • IR (EU) 2025/2621 — default values
    • IR (EU) 2025/2620 — free allocation adjustment
    • IR (EU) 2025/2546 — verification
    • Reg. (EU) 2025/2083 — amending Reg. (EU) 2023/956
    • Del. Reg. (EU) 2025/2551 — accreditation of verifiers

The two formulas

SEEg = AttrEmg / ALg

SEEg = (AttrEmg + EEInpMat) / ALg

Simple and complex goods. A complex good carries the embedded emissions of the Annex I precursors consumed to make it.

Production routes

Ranges are screening bands for data quality, not regulatory limits. A figure outside its band is questioned, never changed.

  • Blast furnace → basic oxygen furnace1.8–2.6 tCO2e/t
  • Direct reduced iron → electric arc furnace0.9–1.9 tCO2e/t
  • Scrap-based electric arc furnace0.2–0.9 tCO2e/t
  • Re-rolling / finishing only0.05–0.4 tCO2e/t

Company and installation

  • Installation name

    Required

    The plant where the CBAM good is produced, as it appears on statutory filings.

    Where it comes from:
    Company registration or factory licence
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV; verification applies at installation level

  • Country of the installation

    Required

    Where the plant physically sits. Drives which default values apply if you file none.

    Where it comes from:
    Factory address
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV

  • UN/LOCODE

    Required

    The UN location code for the installation. A CBAM declaration cannot identify the installation without it.

    Where it comes from:
    UNECE UN/LOCODE list for the nearest recognised location
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV; CBAM Registry operator data

  • Operator legal entity

    Required

    The company legally responsible for the installation, which is who a verifier contracts with.

    Where it comes from:
    Certificate of incorporation
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV

  • Responsible person

    Optional

    Who a verifier calls with a question. Named individual, not a department.

    Where it comes from:
    Internal
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Operational

Product

  • EU CN code

    Required

    The eight-digit Combined Nomenclature code your buyer declares the goods under. Decides whether CBAM applies at all.

    Where it comes from:
    Your EU buyer's customs declaration, or your export invoice HS code mapped to CN
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Export invoice, Buyer customs declaration, Shipping bill
    Rule:
    Reg. (EU) 2023/956 Annex IV Annex I

  • Indian HSN code

    Optional

    Your own tariff code. Kept alongside the CN code so the mapping is auditable rather than assumed.

    Where it comes from:
    GST invoice
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Operational

  • Product name

    Required

    What the plant calls it — hot rolled coil, billet, wire rod.

    Where it comes from:
    Production records
    Effect on the figure:
    Identifies the installation or good
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV

  • EU destination

    Optional

    Which EU member state the goods enter. Determines which importer files the declaration.

    Where it comes from:
    Bill of lading
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Operational

Production

  • Production route

    Required

    How the steel is made. Sets which precursors are expected and which intensity range is plausible.

    Where it comes from:
    Plant engineering
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    IR (EU) 2025/2547; production routes per Annex I

  • Production quantity (t)

    Required

    Tonnes of the good produced in the reporting period. This is ALg — the divisor. An error here scales every figure.

    Where it comes from:
    Production register or ERP production report
    Effect on the figure:
    The divisor — an error scales everything
    Evidence:
    ERP production report, Production register extract, Weighbridge summary
    Rule:
    Reg. (EU) 2023/956 Annex IV — ALg

    Must cover the whole period, not a sample month.

  • Reporting period start

    Required

    First day of the period the data covers.

    Where it comes from:
    Chosen by the operator, normally a financial or calendar year
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    IR (EU) 2025/2547 — reporting period

  • Reporting period end

    Required

    Last day of the period. Must be after the start and not in the future.

    Where it comes from:
    As above
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    IR (EU) 2025/2547 — reporting period

Energy

  • Fuel consumed (t or Nm3)

    Required

    Quantity of each fuel burned in the production process — coal, coke, natural gas, furnace oil, LPG, diesel.

    Where it comes from:
    Fuel purchase invoices reconciled against stock movement
    Effect on the figure:
    Direct emissions
    Evidence:
    Fuel invoice, Stock ledger, Weighbridge record, Gas meter reading
    Rule:
    IR (EU) 2018/2066 — activity data, calculation-based approach

    Purchases alone are not consumption. Opening stock plus purchases minus closing stock is what a verifier reconciles to.

  • Net calorific value (TJ per unit)

    Conditional

    Energy content of the fuel. Combustion streams only.

    Required when: The source stream is a combustion stream

    Where it comes from:
    Supplier fuel analysis certificate, or a national default
    Effect on the figure:
    Direct emissions
    Evidence:
    Supplier fuel analysis certificate, Laboratory report, Published national default
    Rule:
    IR (EU) 2018/2066 Art. 32 — calculation factors

    A supplier certificate beats a default and usually lowers the figure.

  • Emission factor (tCO2e per TJ or per t)

    Required

    tCO2e released per unit of activity data — per TJ for combustion, per tonne for process streams.

    Where it comes from:
    Fuel analysis, or the applicable default factor
    Effect on the figure:
    Direct emissions
    Evidence:
    Laboratory carbon content analysis, Supplier certificate, Cited default factor source
    Rule:
    IR (EU) 2018/2066 Art. 32–35

    If you use a default, cite which one. An uncited factor is a finding.

  • Oxidation or conversion factor

    Optional

    Fraction of carbon actually oxidised. Defaults to 1 when not measured, which is conservative.

    Where it comes from:
    Plant measurement, otherwise leave blank
    Effect on the figure:
    Direct emissions
    Evidence:
    Not required
    Rule:
    IR (EU) 2018/2066 Art. 36

    Only claim below 1 if you can evidence unburnt carbon.

  • Purchased electricity (kWh)

    Required

    Electricity drawn for the production process. For steel, indirect emissions are reported but do not carry the CBAM charge — report them accurately anyway, your buyer asks.

    Where it comes from:
    Electricity bills, plant sub-meters
    Effect on the figure:
    Indirect emissions
    Evidence:
    Electricity bill, Sub-meter reading, DISCOM statement, Open-access settlement
    Rule:
    IR (EU) 2025/2547 — indirect emissions

  • Electricity source

    Required

    Grid, power purchase agreement, or captive generation. Decides which emission factor is defensible.

    Where it comes from:
    Procurement records
    Effect on the figure:
    Indirect emissions
    Evidence:
    Power purchase agreement, Open-access approval, Captive plant licence
    Rule:
    IR (EU) 2025/2547 — electricity emission factors

    A PPA factor below grid average needs the contract attached, or it reverts to grid.

  • Electricity emission factor (tCO2e/MWh)

    Required

    tCO2e per MWh for the electricity consumed.

    Where it comes from:
    Grid average for the region, or the contracted factor for a PPA
    Effect on the figure:
    Indirect emissions
    Evidence:
    Cited grid factor source, PPA contract, Generation attribute certificate
    Rule:
    IR (EU) 2025/2547 — indirect emissions

Raw materials and precursors

  • Precursor material

    Conditional

    An Annex I good consumed to make this one — pig iron, DRI, ferro-alloys, crude steel. Carries its own emissions into yours.

    Required when: The production route consumes precursors, which is every route except pure scrap melting

    Where it comes from:
    Purchase records
    Effect on the figure:
    Precursor emissions
    Evidence:
    Purchase invoice, Goods receipt note, Supplier delivery challan
    Rule:
    Reg. (EU) 2023/956 Annex IV Annex IV — EEInpMat

  • Precursor quantity (t)

    Conditional

    Tonnes of the precursor consumed in the period.

    Required when: A precursor is declared

    Where it comes from:
    Stock ledger
    Effect on the figure:
    Precursor emissions
    Evidence:
    Stock ledger, Goods receipt note, Weighbridge record
    Rule:
    Reg. (EU) 2023/956 Annex IV Annex IV — EEInpMat

  • Precursor embedded emissions (tCO2e/t)

    Conditional

    The supplier's own specific embedded emissions, tCO2e per tonne. If they will not tell you, a default applies — and defaults carry a mark-up.

    Required when: A precursor is declared

    Where it comes from:
    The supplier. This is the hardest number in the whole exercise to obtain.
    Effect on the figure:
    Precursor emissions
    Evidence:
    Supplier CBAM data sheet, Supplier's verified report, Supplier questionnaire response
    Rule:
    Reg. (EU) 2023/956 Annex IV Annex IV — EEInpMat

    An unverified supplier figure is still better than a default, but must be labelled as unverified.

  • Precursor figure verified

    Conditional

    Whether the supplier's figure has itself been through accredited verification.

    Required when: A precursor is declared

    Where it comes from:
    Supplier's verification statement
    Effect on the figure:
    Precursor emissions
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV Art. 8 — verification

  • Scrap share of metallic charge (%)

    Optional

    Proportion of the metallic input that is scrap. Not a CBAM input directly, but the single strongest explanation for why your intensity differs from a default.

    Where it comes from:
    Charge records
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Operational — supports the narrative to a verifier

Data quality

  • How the quantity was established

    Required

    Measured, invoiced or estimated. Drives the confidence grade and is the first thing a verifier samples.

    Where it comes from:
    Whoever recorded the figure
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    IR (EU) 2018/2066 — tiers and uncertainty

    Estimated values are accepted but always raise a finding.

  • Electricity intensity (MWh/t)

    Optional

    Derived, not entered: MWh per tonne of product. Exists so a unit error or a missing production month is caught before a verifier finds it.

    Where it comes from:
    Derived from electricity and production quantity
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Operational — data quality screen

  • Specific embedded emissions (tCO2e/t)

    Optional

    Derived: the figure your buyer declares. Screened against the plausible range for the route.

    Where it comes from:
    Derived by the calculation engine
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    Not required
    Rule:
    Reg. (EU) 2023/956 Annex IV Annex IV — SEEg

Evidence

  • Supporting document

    Required

    The file that substantiates a figure. Every document records what it supports, who uploaded it and when.

    Where it comes from:
    The exporter's own records
    Effect on the figure:
    Context, does not change the figure
    Evidence:
    PDF, Photograph of a paper register, Spreadsheet export, ERP report
    Rule:
    Reg. (EU) 2023/956 Annex IV Art. 8 — verification; IR (EU) 2018/2066 — record keeping

    A photograph of a paper register is acceptable evidence. Illegibility is what fails, not the format.

Machine-readable at /api/v1/cbam/dictionary. Verdex prepares evidence and does not verify. Actual embedded emissions may be used in a CBAM declaration once verified by a body accredited under Reg. (EC) 765/2008 by an EU or EEA national accreditation body.