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Are emission factors from life-cycle assessments (LCA) / life-cycle inventory databases accepted?

No, emission factors from life-cycle assessments (LCA)/life-cycle inventory databases are not accepted for calculating embedded emissions in the CBAM report. Note, however, that until 30 June 2024, i.e. reports due until 31 July 2024, for each import of goods for which the reporting declarant does not have all the information, the reporting declarant may use other methods for determining the emissions. In this limited time, emission factors from life-cycle assessments (LCA)/life-cycle inventory database may be used. Moreover, if the embedded emissions are determined using one of the eligible monitoring and reporting methods described in Article 4(2) of Implementing Regulation (EU) 2023/1773 and that method uses emission factors from life-cycle assessments, this is also possible until the end of 2024.

As is explained in the guidance document for non-EU operators, section 6.2.1 and Table 6-1, the concept of embedded emissions is narrower than the scope of life-cycle assessments (LCA) and product carbon footprints (PCF). The use of emission factors from LCA databases therefore significantly over-estimate the embedded emissions. This is counter the design of the CBAM which aims at mirroring the emissions covered by the EU ETS. In the definitive phase, importers would be required to surrender too many CBAM certificates if they used these emission factors.

However, it cannot be excluded that the providers of LCA databases develop CBAM- compatible datasets in the future. Operators of installations producing CBAM goods would be able to use such databases, provided the database documentation provides evidence that the system boundaries underlying the database values are suitable for the CBAM, as operators are responsible for reporting correct data.

Source: EC’s Questions and Answers on CBAM .

CBAM Regulation and Guidance document for non-EU installations

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