The SEE formula is simple to state. Getting a defensible, verifiable number into it requires a monitoring plan that documents exactly where every data point comes from.
Last verified: 02 September 2026
Article 8 of EU Regulation 2023/956 requires operators to document exactly how their embedded emissions data is produced — not just report a final tCO₂e figure. This documentation is the monitoring plan: the methodology, data sources, and control procedures behind every number that eventually feeds the SEE calculation.
It's what a verifier actually reviews (see our verification requirements page) — not the final number in isolation, but whether the process that produced it is sound and consistently applied.
A monitoring plan doesn't treat "all emissions" as one aggregate figure. It breaks the installation down into source streams — individual fuels, raw materials, and purchased precursors — each documented with its own data source, measurement method, and uncertainty assessment. Per EU IR 2025/2547 Annex II §A.5.7, any use of a simplified method (like mass-balance) instead of direct measurement needs its own explicit justification, not a blanket assumption.
Every installation's plan needs these elements, regardless of sector:
| Category | Elements |
|---|---|
| Methodology | Methodology description, methodology justification, uncertainty assessment |
| Data | Data sources, metering points, source streams, equipment calibrations |
| Scope | Installation overview, non-CBAM goods, precursor methodology, heat/electricity allocation |
| Governance | Control system description, personnel training, change-management procedure, revision period |
| Reference | Competent authority reference, CBAM benchmark reference |
On top of those, some elements apply only when they're actually relevant to the installation:
| Condition | Additional element required |
|---|---|
| Installation is in the aluminium sector | PFC monitoring methodology |
| Installation uses zero-rated fuels | Zero-rated fuels justification |
| Installation produces or uses waste gas | Waste gas detail |
| Installation uses CO₂ capture | Responsible person name and contact for CO₂ capture |
| Installation produces electricity | Electricity source type |
A plan should never be penalised for a field that genuinely doesn't apply to it — but it also shouldn't skip a conditional element just because it's easy to overlook. If your installation produces electricity or uses CO₂ capture, that element is not optional.
Aluminium-sector installations specifically: see our aluminium PFC and anode-effect guide for how the PFC monitoring methodology element is actually calculated.
The SEE formula (direct + indirect embedded emissions, divided by net production) tells you what to calculate. The monitoring plan tells you — and your verifier — exactly how each number that feeds that formula was measured, sourced, and controlled. One is arithmetic; the other is the evidence trail behind it.