EU CBAM Indirect Emissions Study: What It Signals

The Commission’s technical study on indirect emissions looks at how electricity-related emissions could be handled in CBAM. It examines default factors, possible conditions for claiming actual indirect emissions, and possible extension of indirect-emissions coverage to other goods or sectors (O — analytical study).

Those are important questions, but the document’s status is equally important. The study is analytical. It does not change current CBAM scope, create a new evidence route or announce an adopted electricity methodology.

Why default-factor design is difficult

The study compares possible approaches to indirect-emissions default factors against criteria such as environmental integrity, representativeness, data availability, conservativeness and administrative feasibility (O — analytical study).

A broad country or grid average may be easier to operate. A more selective factor may better distinguish electricity sources, but it can increase data and governance demands. The study also highlights the risk of resource shuffling: a design may encourage market participants to assign cleaner electricity to reported production without changing the wider physical emissions outcome (O — analytical study).

This is why updating and governance matter in the analysis. A default factor is not just a number. Its geographic basis, time period, data source and version can influence incentives. Systems should therefore avoid hard-coding any study option as though it were an established rule.

What actual indirect-emissions claims might need

For direct technical links, the study discusses physical connectivity, traceable electricity flows, technical documentation, interval or smart metering, time-matched data, linked contracts and verification able to reconcile flows, losses and claims (O — analytical study).

For power purchase agreements, or PPAs, the analysis distinguishes physical arrangements from financial or virtual arrangements. It considers energy-attribute certificates, temporal and geographic correlation, additionality, exclusivity and double-claim controls (O — analytical study).

The central issue is whether a contractual claim corresponds sufficiently to the electricity associated with production. The study does not establish a new PPA test. It maps evidence and integrity questions that policymakers would need to resolve before any different route could become law.

Extension is a scenario, not a rule

The study also examines whether indirect-emissions coverage could extend beyond the goods or sectors currently covered. It weighs carbon-leakage protection and parity with EU producers against data burden, verification cost and legal or administrative complexity (O — analytical study).

Some phased or compensation-linked approaches are discussed as comparatively feasible policy options (O — analytical study). That is not an extension decision. Any change to scope would require legislation, and the study itself provides no basis for treating additional goods as covered today.

Companies should therefore keep current-law determinations separate from outlook work. A scenario register may note the study, but customs classification, scope decisions and declarations must continue to follow the law in force.

Prepare adaptable evidence without pre-empting policy

The study does offer a sensible preparedness lesson: preserve electricity evidence in a structured form. Producers can retain meter records, contracts, certificates, grid or source attribution and the reconciliation between electricity use and production. Systems can keep physical electricity data separate from contractual environmental attributes and version the factor or method applied.

Procurement and sustainability teams should also record exclusivity and possible double counting rather than assuming a certificate settles the emissions question. These steps improve evidence quality without claiming that a future option has been adopted.

Review whether your data model can distinguish physical consumption, contractual claims and the calculation parameter used. Track later legislation or formal proposals separately. Use the study to test readiness, not to rewrite current compliance rules.

Source note: This article summarises the Commission-commissioned study package published on 8 June 2026 (O — analytical study). The study is not law, guidance, a formal proposal or an official decision to extend CBAM.