A steel exporter → CBAM quarterly actual values + China ETS compliance
Steel is both a CBAM priority category and a newly covered sector in China’s ETS. The company used one emissions data foundation to file CBAM actual-value quarterly reports abroad and meet China-ETS compliance at home.
This case is fully anonymised and refers to no specific customer.
- One data setshared by CBAM & China ETS
- Process-levelallocable dual-route embedded emissions
- 30–40%potential savings: actual vs default
- Quarterlyauto-generated CBAM reports
Customer: A steel exporter (blast + basic-oxygen dual process, part of output to the EU)
Background
- Industry
- Steel
- Solution
- Overseas Compliance
- Customer
- A steel exporter (blast + basic-oxygen dual process, part of output to the EU)
The company runs blast-furnace and basic-oxygen processes, exporting part of its steel to the EU. The CBAM definitive period requires importers to report embedded emissions on actual values sourced from the exporter; meanwhile steel has entered China’s ETS expansion, requiring accounting and compliance under the Ministry of Ecology and Environment. Both rest on process-level emission data, yet the customer reported domestically and internationally on separate tracks — duplicated collection, inconsistent definitions — and process allocation across the dual route was a persistent accounting headache.
The challenge
Under the twin pressure of compliance and cost, these were the core problems.
CBAM actual values require process-level embedded emissions; dual-route allocation is complex and error-prone.
CBAM abroad and China-ETS at home are reported separately — duplicate collection, clashing definitions.
Default values are well above actual; keeping them inflates importer tariffs and erodes competitiveness.
The AMT approach
From the data foundation to compliant delivery — phased, end to end.
- 1Process-level data foundation
The L1 platform plus organization-carbon aggregate energy and emissions across both routes, establishing an allocable process-level basis.
- 2CBAM actual-value accounting
PCF computes steel embedded emissions per CBAM methodology, auto-generating quarterly and annual report fields.
- 3China-ETS compliance
The same emissions data feeds China-ETS accounting and allowance management for domestic compliance.
- 4Verification-ready
Third-party-assurance enablement builds an evidence pack supporting both CBAM and domestic verification.
Outcomes
Beyond compliance — quantifiable savings and efficiency.
All figures are anonymised and shown as indicative ranges; they do not refer to any specific customer.
“Process allocation across our dual route is the hardest part of steel CBAM. Once that was hard-wired into the system, quarterly reporting went from “redo each time” to “review each time”.”
Shared within NDA limits · anonymised
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