CBAM 2025: How the Correction of Embedded Emissions Calculation Affects Steel, Cement, and Aluminum Importers

Key data

European importers of carbon-intensive industrial products have an immediate obligation: to review and, where appropriate, correct the procedures they use to calculate embedded emissions in their goods. Commission Implementing Regulation (EU) 2025/2547, which develops the technical procedures of the Carbon Border Adjustment Mechanism (CBAM), has been subject to a formal correction published on June 3, 2026 with retroactive effect from December 22, 2025.

CBAM, established by Regulation (EU) 2023/956 of the European Parliament and of the Council, requires importers of certain products to declare and pay for the CO₂ emissions implicit in their production outside the EU. This correction directly affects the calculation methods, formulas, or regulatory references that must be applied to comply with that declaration.

What does this regulation establish?

Commission Implementing Regulation (EU) 2025/2547 develops the technical procedures for calculating embedded emissions —also called "grey" emissions— in imported goods subject to CBAM. The correction published under reference CELEX:32025R2547R(01) amends errors or inaccuracies in calculation methods, formulas, or regulatory references contained in that implementing regulation.

The products affected by CBAM —and therefore by this correction— are the following:

The correction may affect any of the following elements of the original regulation: methods for calculating direct and indirect emissions, conversion formulas, references to technical standards, or default values applicable when data from the foreign producer is not available.

Economic and operational impact

The impact of this correction is not merely formal. Applying an incorrect calculation method —whether the one prior to the correction or one that does not reflect the changes introduced— can result in significant economic sanctions, as established by the CBAM regulatory framework itself.

From an operational perspective, affected companies must assume the following costs and efforts:

• Review of internal procedures for calculating embedded emissions, with possible need to update carbon footprint management tools or software.
• Coordination with foreign suppliers to obtain updated emissions data compliant with the corrected version of the regulation.
• Update of CBAM declarations if those submitted since December 22, 2025 were based on the uncorrected version of the regulation.
• Training of the compliance team on the changes introduced by the correction.

The risk of inaction is twofold: sanctions for incorrect declaration and possible retroactive adjustments in the number of CBAM certificates to be acquired, which can represent an additional economic cost not foreseen in the import budget.

Who does it affect?

This correction directly affects all companies that import into the European Union any of the products subject to CBAM. Specifically:

• European importers of steel and steel products from third countries.
• Importers of cement and clinker.
• Importers of aluminum and its derivatives.
• Importers of nitrogen fertilizers.
• Operators that import electricity from non-EU countries.
• Importers of hydrogen.
• Advisors, consultants, and regulatory compliance departments that manage CBAM declarations for their clients.
• CFOs and operations directors of industrial companies with supply chains outside the EU.

Practical example

A Spanish importer of steel profiles from Turkey has the obligation to declare, in its CBAM report, the CO₂ emissions embedded in each ton of imported steel. To do this, it applies the technical procedures of Commission Implementing Regulation (EU) 2025/2547.

If that importer continued to apply the calculation methods of the original version of the regulation —without incorporating the correction published under CELEX:32025R2547R(01)— since December 22, 2025, its CBAM declarations may contain errors in the formulas or regulatory references used. This exposes it to the competent authority detecting the discrepancy, requiring a corrective declaration, and, where appropriate, imposing the significant economic sanctions provided for by the CBAM framework.

The immediate action in this case is: identify which specific elements of the regulation have been corrected, compare with the procedures applied since December 2025, and, if there are differences, submit the appropriate corrections to the competent national authority.

What should companies do now?

1. Access the corrected text of Commission Implementing Regulation (EU) 2025/2547 (CELEX:32025R2547R(01)) in the Official Journal of the EU and identify exactly which calculation methods, formulas, or references have been modified.
2. Audit CBAM declarations submitted since December 22, 2025 to verify whether the correct procedures or those of the uncorrected version were applied.
3. Update internal procedures for calculating embedded emissions to reflect the corrected version of the regulation, including tools, templates, and internal guides.
4. Contact foreign suppliers to ensure that the emissions data they provide is compatible with the corrected calculation methods.
5. Submit corrective declarations if errors are detected in those already submitted, before the competent authority detects them, to minimize the risk of sanctions.
6. Train the compliance team on the content of the correction and its practical implications in the CBAM declaration process.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32025R2547R(01)