Steel & Cement CBAM Annex I BRSR Mandatory

Audit-ready Scope 1 & 2 reporting
for steel and cement.

Steel and cement are among the most carbon-intensive manufacturing sectors — and among the most regulated. India's large steel and cement producers face mandatory BRSR filing, CCTS GEI reduction targets, and the most immediate CBAM compliance exposure of any Indian manufacturing sector.

CBAM — Definitive Phase Active from January 2026

The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. Steel and cement are in CBAM Annex I. Indian exporters of steel and cement products to the EU must now report embedded carbon emissions using the CBAM methodology. Carbon documentation is no longer optional — it is a market access requirement with direct financial consequences.

For large listed steel and cement companies, BRSR Principal 6 mandates annual Scope 1 and Scope 2 disclosure. India's CCTS covers both sectors with PAT scheme integration — energy savings and GEI reduction targets apply simultaneously. Sustaineve provides the GHG accounting baseline required across all three frameworks.

CBAM Compliance Status — Steel & Cement

EU Carbon Border Adjustment Mechanism

CBAM Annex I coverage

Active 2026

Embedded carbon reporting required

Mandatory

CBAM certificates obligation

Annual

GHG Protocol methodology accepted

Confirmed

Indian exporter registration

Required

Also applicable

BRSR P6

Mandatory for large listed companies

India CCTS

PAT scheme + GEI reduction targets

ISO 14064

Audit-ready verification support

High-intensity, multi-source — all categories handled.

Steel — Emission Sources

Blast furnace — coking coal combustion

Scope 1
Very High

Process emissions — direct reduction iron

Scope 1
Very High

Electric arc furnace — purchased electricity

Scope 2
High

Auxiliary fuel combustion — ladles, reheating

Scope 1
Medium–High

Fugitive — coke oven gas leaks

Scope 1
Medium

Cement — Emission Sources

Calcination — CaCO₃ to CaO process

Scope 1
Very High

Kiln fuel combustion — coal, pet coke, gas

Scope 1
Very High

Clinker production process emissions

Scope 1
High

Purchased electricity — grinding, conveyors

Scope 2
Medium–High

On-site transport fleet

Scope 1
Low–Medium

Calcination: the process emission that most manufacturers miss

In cement production, calcination — the conversion of limestone (CaCO₃) to lime (CaO) — releases CO₂ as a direct chemical reaction, not from fuel combustion. This is a Scope 1 process emission that is separate from and in addition to kiln fuel combustion. For cement producers, process emissions from calcination typically account for 50–65% of total Scope 1. Failing to account for this in a CBAM or BRSR submission is a material under-disclosure. Sustaineve's process emission category captures this correctly.

Scope 1 process emissions explained →

CBAM is active. BRSR is mandatory.
Your baseline needs to exist.

Scope 1 and Scope 2 accounting with CBAM-aware methodology. First report within one week.