Which cement goods are in CBAM, by CN code, and why white and grey clinker are priced apart

By Ahmed Medhat · Published14 October 2026

Cement is the sector where an eight-digit CN code is not always enough to price a tonne. Annex I to Regulation (EU) 2023/956 lists six cement lines. Two of them each cover a white good and a grey good, and the default values for the two are not the same.

The six cement lines in Annex I

Annex I lists these goods under "Cement", each with carbon dioxide as the greenhouse gas:

• ex 2507 00 80: Other kaolinic clays except non-calcined kaolinic clays
• 2523 10 00: Cement clinkers
• 2523 21 00: White Portland cement, whether or not artificially coloured
• 2523 29 00: Other Portland cement
• 2523 30 00: Aluminous cement
• 2523 90 00: Other hydraulic cements

The first line was narrowed by Regulation (EU) 2025/2083, which replaced "2507 00 80 – Other kaolinic clays" with the "ex" line above. Kaolinic clay that has not been calcined is outside CBAM.

Two codes, four goods

Implementing Regulation (EU) 2026/1740, which corrected the default-value tables, explains why two of the codes are split: "As regards CN code 2523 10 00 in all the tables in Annexes I and IV to Implementing Regulation (EU) 2025/2621, different default values apply to white clinker and grey clinker. The same applies to the default values for white hydraulic cement and grey hydraulic cements under CN code 2523 90 00 in those Annexes. In order to reflect those differences more clearly, TARIC codes should be used to distinguish between those goods" (recital (5)).

So the corrected default-value tables carry no value at the eight-digit codes 2523 10 00 and 2523 90 00. They carry four ten-digit TARIC lines instead:

• 2523 10 00 10: White clinker
• 2523 10 00 90: Other clinker including grey clinker
• 2523 90 00 10: White hydraulic cement
• 2523 90 00 90: Other hydraulic cements including grey hydraulic cements

Portland cement needs no split, because the CN already separates it: 2523 21 00 is white, and the tables label 2523 29 00 "Grey Portland cement". Calcined clay appears in the tables as TARIC 2507 00 80 80.

If you sell clinker or other hydraulic cement into the EU, your buyer needs to know which of the two lines your good is. The eight digits on the invoice do not say.

What the split changes, for a tonne from Egypt

The tables give three values per good: direct, indirect and total emissions, in tonnes of CO2e per tonne of good. The number of CBAM certificates is calculated from the total, increased by a mark-up that for cement is 10 % for 2026, 20 % for 2027 and 30 % from 2028 (Implementing Regulation (EU) 2026/1740, Annex I).

Egypt's totals for the split goods:

• White clinker 1.330 against grey clinker 1.270
• White hydraulic cement 1.450 against grey hydraulic cements 1.240
• White Portland cement 1.390 against grey Portland cement 1.290

With the 2026 mark-up, a tonne of white clinker from Egypt is priced on 1.463 tonnes of CO2e and a tonne of grey clinker on 1.397, before the free allocation adjustment. For other hydraulic cements the gap is wider: 1.595 against 1.364.

Where a country shows "–"

Not every listed country has a cement value. The act's rule: "Where a country or territory is explicitly listed but no value is provided or the relevant field shows '–', the default value for the respective good from the table 'Other countries and territories' needs to be selected" (Implementing Regulation (EU) 2026/1740, Annex I).

Türkiye is an example. Its table gives a value only for aluminous cement (1.950 total). Every other cement line falls to the "Other Countries and Territories" table, where grey clinker is 1.410 and white clinker 1.370. Here, white clinker is the lower of the two. The split does not always run the same way, so our calculators have you choose white or grey clinker before they price it.

Route (A) and route (B)

The tables also mark each split line that carries a value with a production route, and the act gives their meaning: "(A) grey clinker / cement" and "(B) white clinker / cement" (Implementing Regulation (EU) 2026/1740, Annex I). The route decides which CBAM benchmark is used to calculate the free allocation adjustment. Where default values are used, "the same production route shall be used as indicated in Annex I to Commission Implementing Regulation (EU) 2025/2621" for the country of origin (Implementing Regulation (EU) 2025/2620, Annex, point 5.1).

With actual data, the act defines the two clinkers. White cement clinker is clinker for use as the main binding component in materials such as ceramic tile adhesives, repair mortars and ready-mixed plaster, with maximum average contents of 0.4 mass-% Fe2O3, 0.003 mass-% Cr2O3 and 0.03 mass-% Mn2O3. Grey cement clinker "means other cement clinker than white cement clinker" (Implementing Regulation (EU) 2025/2620, Annex, point 5.2.1).

A mix of white and grey clinker

A hydraulic cement under 2523 90 00 can contain both, with or without calcined clay. With actual data, "the CBAM benchmark shall be calculated as a weighted average that reflects the composition" (Implementing Regulation (EU) 2025/2620, Annex, point 5.2.1). With default values, the good takes the route of the default line it is priced on (point 5.1). The act does not say which of the two TARIC lines a mixed cement falls under; that is a customs classification. Our reading: a mix is not white, so it takes the "Other hydraulic cements including grey hydraulic cements" line, route (A). Confirm the line with your customs broker.

What to tell your buyer, and what to check

State the ten-digit TARIC line, not only the CN code, for clinker and for other hydraulic cements. If you say the clinker is white, check it against point 5.2.1, which defines white cement clinker by its use and by its maximum oxide contents.

Our sector cost calculator lists white clinker and grey clinker as separate choices, and our default-value cost calculator asks whether your clinker is white or grey before it prices it. Neither prices other hydraulic cements (2523 90 00) yet.