Your buyer asked for a product carbon footprint. Is that the same as CBAM?

Buyers increasingly ask for both a product carbon footprint and CBAM data. They look similar but measure different things.

Reviewed by the Carbon Passport compliance team, Singapore. Updated and checked against official EU sources on 28 September 2026. Rules change often; we update this page when they do.

Quick answer

A product carbon footprint is not the same as CBAM data. A PCF usually includes electricity and other upstream emissions, while CBAM for aluminium and most steel goods counts direct emissions only. Send each figure for its own purpose and label it clearly.

What this request is

A product carbon footprint (PCF) is a cradle-to-gate or cradle-to-grave estimate of all greenhouse gas emissions linked to a product, often following standards such as ISO 14067 or the GHG Protocol product standard. Buyers use it for their own Scope 3 reporting, product labels or customer claims.

Why your buyer is asking

Your buyer may need a PCF for its climate reporting and CBAM data for its customs declaration. Different teams often ask separately, and sometimes the request mixes the two.

What to send

  1. A clear statement of which figure the buyer needs, and for what purpose
  2. For CBAM: embedded emissions per tonne by the EU method
  3. For a PCF: the footprint, the standard used and what's included
  4. Labels on each figure so neither is used in place of the other

Be careful about

  • Sending a PCF as CBAM data. It includes electricity and other items CBAM excludes for metals
  • Sending CBAM data as a PCF. It leaves out electricity, so it understates your footprint
  • Different reporting periods for the two figures without saying so

A reply you can adapt

Dear [name],

Thank you for your request. To make sure we send the right figure: do you need our product carbon footprint for your climate reporting, or our embedded emissions under EU CBAM for your customs declaration? They're calculated differently.

We can provide both for [product] for [period], clearly labelled.

Kind regards,
[name]

Keep a copy of everything you send. The same buyer will ask again next year, and other buyers will ask for the same data.

Got a request you're not sure about?

Send us what your buyer sent. We'll tell you what they need and what it will take, free, within one week.

Send your request

Frequently asked questions

Is a product carbon footprint the same as CBAM data?

No. A PCF usually covers electricity and other upstream emissions. CBAM for aluminium and most steel goods counts direct emissions only.

Why is my CBAM figure lower than my carbon footprint?

Because CBAM excludes electricity for these goods and follows its own system boundaries.

Can I reuse my data for both?

Yes, the underlying records are the same. The calculations and boundaries differ.

Sources

This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.

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