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CBAM Wants Embedded Emissions per Product. Your Data Is per Site.

Written by Scott Rogers | Oct 2, 2026, 1:16:01 PM

Carbon border rules ask for emissions at the level of the product you ship. Most manufacturers can only report at the level of the site they run. This article shows how the same connected foundation closes that gap before the deadline does.

UK CBAM begins
2027

From 1st January 2027 the UK prices carbon on imported aluminium, cement, fertiliser, hydrogen and iron and steel, above £50,000 over a rolling 12 months. (HMRC, Autumn Budget 2025)

 2027

CBAM changes what carbon reporting has to prove. It is no longer a site-level total in a sustainability report. It is embedded emissions attributed to the specific goods you make and sell, in a form an importer and an auditor will accept. That is a product-level question asked of data that is almost always held at site level.

For a CFO, that is a new liability and a new reporting burden arriving on a fixed date. For a Head of Sustainability, it is the moment carbon stops being an annual disclosure and becomes a number attached to every consignment. Both need the same thing: emissions they can trace to a product, not just to a plant.

Why is CBAM a data problem, not just a reporting one?

Because the figure CBAM asks for does not exist in most manufacturers' systems yet. Energy and emissions are metered at site or building level. CBAM wants them at product and consignment level, split by production route and process step, with an audit trail back to the source data. Bridging the two means joining energy, production and material data and attributing it to the batch and product it belongs to. That is the same connected foundation the energy and OTIF use cases depend on, pointed at carbon.

✓Energy and meter data: how much was consumed, where and when.
✓Production and material data: what was made, on which route, from which inputs.
✓The join between them: emissions attributed to a product and a consignment, not a site.

What does connected carbon data give you?

The same product-level foundation, serving a new question.

✓Embedded emissions per product and process step, not just a site total.
✓An audit trail from meter and material data through to the reported figure, which is what an importer and a verifier will ask for.
✓Reuse of the product-level energy model you may already be building, rather than a separate, standalone carbon project.

Report actual emissions and you can prove a genuinely lower-carbon product where you have one. Fall back on default values, which CBAM allows when actual data is missing, and you risk paying against a conservative benchmark that sits higher than your real footprint. Good data is not only compliance. It can be a lower bill.

What is at stake, and by when?

Proof2027From 1st January 2027 the UK's CBAM places a carbon price on imports of aluminium, cement, fertiliser, hydrogen, and iron and steel. Liability starts once you bring in more than £50,000 of CBAM goods over a rolling 12 months.HMRC / HM Treasury, Autumn Budget 2025

The deadline cuts two ways. If you import any of those materials, you carry a CBAM liability from 2027 and need embedded-emissions data from your suppliers to calculate it, or you pay against default values. If you sell into the EU, the pressure is already here: the EU's own CBAM entered its definitive phase in 2026, so your EU customers are asking for verified embedded emissions per product now. Either way the data has to be product-level, attributable and auditable, and building that takes longer than the notice the deadline gives you.

Indirect emissions sit outside the UK scheme until 2029 at the earliest, and the rate is set quarterly, but the reporting obligation and the £50,000 threshold are fixed from January 2027. The time to connect the data is before the first return is due, not after.

Where should you start?

✓Start with the product lines exposed to CBAM, whether through imported inputs or EU sales.
✓Connect energy, production and material data for that scope, and attribute it to product and batch.
✓Build the audit trail once, so the reported figure traces back to source data a verifier will accept.
✓Reuse the product-level energy model rather than standing up a separate carbon project.

The right tools depend on your environment, not a vendor preference. In practice this often means Fivetran or Talend to connect energy, production and material data, Snowflake or Databricks to model it with full lineage using dbt and DataOps.Live, and Qlik to report embedded emissions per product with an audit trail a verifier will accept. We build across the modern data stack and choose what fits the data you already hold.

Product-level energy and product-level carbon are the same data problem asked twice. Connect the foundation once, and CBAM becomes a report you can run rather than a deadline you are chasing.

The same foundation, one deadline earlier.

Product-level energy and product-level carbon are the same data problem. See how connected your operation is before the deadline decides for you.

Sources
1.HM Treasury and HMRC, Autumn Budget 2025: UK CBAM from 1 January 2027; £50,000 rolling 12-month registration threshold; scope aluminium, cement, fertiliser, hydrogen, iron and steel; indirect emissions excluded until 2029 at the earliest; rate set quarterly; legislating in the Finance Bill 2025-26.
2.European Commission: the EU CBAM definitive period began in 2026, placing financial obligations on EU importers of covered goods.
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