BRSR for Cement — Material Disclosures, Process Emissions, and EU CBAM Exposure

Why this guide exists

Indian listed cement entities sit at a uniquely demanding intersection within the Top 1,000 listed-entity cohort by market capitalisation. Cement is the most GHG-intensive sector in BRSR scope: roughly half of a typical integrated cement plant’s Scope 1 footprint comes from process emissions (the calcination of limestone — a chemical reaction releasing CO₂ that has nothing to do with fuel combustion), with the remainder from kiln fuel and on-site power generation.

This guide walks through the BRSR-specific patterns observed for Indian listed cement entities — the Core attributes that tend to be most material in practice, the process-vs-combustion Scope 1 split, the sector-specific operational levers (Alternative Fuel Ratio, clinker-to-cement ratio, Waste Heat Recovery, co-processing), Captive Power Plant boundary mechanics, and how the BRSR submission intersects with the EU Carbon Border Adjustment Mechanism (CBAM) — a parallel regime that lands directly on Indian cement exporters to the EU.

This guide describes common BRSR disclosure patterns for the cement sector, but entity-level materiality, current SEBI phase-in applicability, the assurance standard applied, and CBAM exposure should always be confirmed for the specific listed entity.

The cement profile within the Top 1,000

Common sectoral features observed in Indian listed cement BRSR disclosures (these shape the disclosure profile in practice but are not a SEBI-prescribed sector taxonomy):

• NIC classification — Cement manufacturing is typically classified under NIC division 23 (Manufacture of other non-metallic mineral products), specifically NIC 2394 (Manufacture of cement, lime and plaster). Ready-Mix Concrete (RMC) operations frequently sit under NIC 2395.
• Integrated + split-grinding plant footprint — Listed cement entities commonly operate a mix of integrated cement plants (located near limestone reserves, housing the kiln and clinker production), standalone grinding units (located near market clusters and major fly-ash sources such as thermal power plants), and RMC batching plants (distributed near construction-demand centres).
• Captive limestone mining — Most integrated plants operate captive limestone (and sometimes coal / fly-ash) mines under MMDR Act leases. Mine operations are part of the reporting boundary and frequently dominate the entity’s safety / land-use / biodiversity narrative.
• Captive Power Plants (CPPs) + Waste Heat Recovery — Integrated plants commonly operate CPPs (coal-fired, sometimes gas) for power reliability, plus increasing WHRS deployments to recover exhaust heat from the kiln preheater and cooler.
• Heavy logistics footprint — Movement of limestone, coal, petcoke, fly ash, slag, and finished cement (bulk + bagged) occurs predominantly via rail and road, generating substantial Scope 3 transportation emissions.
• CBAM exposure for EU exporters — Cement is one of the six initial CBAM-scoped sectors. Indian cement exporters to the EU face a parallel quarterly embedded-emissions reporting regime distinct from BRSR.

Material BRSR Core attributes for cement

The BRSR Core (per SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023) is structured around 9 ESG attributes. The materiality of each attribute for a cement entity is entity-specific, but the patterns commonly observed in published submissions are:

BRSR Core attribute	NGRBC Principle	Typical materiality for cement	Sector notes
GHG emission intensity per revenue (Scope 1 + 2)	P6	The defining Core attribute — typically the highest-intensity sector in BRSR scope	Driven by calcination process emissions (~half) + kiln-fuel combustion + CPP coal. See GHG emission intensity per revenue and CEA Grid Emission Factors.
Water withdrawal intensity	P6	Typically material — driven by equipment cooling, mine dust suppression, CPP cooling	See Water withdrawal intensity.
Job creation in smaller towns	P8	Typically substantive — integrated plants and mines are almost always in non-metro / semi-rural locations	See Job creation in smaller towns.
Spend on wellbeing	P3	Typically substantive — mining + kiln operations carry elevated occupational health and safety risk profiles	Mine safety and respirable-dust exposure programmes commonly featured. See Spend on wellbeing.
Openness of business (related-party transactions)	P1	Typically moderate; can be material for group structures with captive logistics / power / RMC subsidiaries	See Openness of business.
Gross wages paid to women	P5	Typically moderate disclosure	Heavy-manufacturing and mining workforces historically have low gender ratios; sector-wide trajectory is improving. See Female wages disclosure.
Complaints disclosure (POSH)	P5	Typically substantive disclosure given workforce size	See POSH complaints disclosure.

The materiality column reflects patterns observed in published Indian cement BRSR submissions — entity-level materiality assessment is the framework that should drive actual reporting emphasis. See the Materiality Assessment Walkthrough.

Sector-specific patterns by area

Process emissions (calcination) vs energy emissions

The most important technical distinction in cement Scope 1 reporting is that two physically distinct emission sources sit inside the same Scope 1 envelope:

• Process emissions — calcination of calcium carbonate (limestone) into calcium oxide releases CO₂ as a stoichiometric output of the chemical reaction: CaCO₃ → CaO + CO₂. This CO₂ is unavoidable in conventional Portland clinker production, regardless of fuel choice. It accounts for approximately half of a typical integrated cement plant’s Scope 1 footprint (the share varies plant-to-plant with clinker-to-cement ratio and raw-meal composition).
• Combustion / energy emissions — fuel burned in the kiln (coal, petcoke, alternative fuels such as RDF / biomass / used tyres / hazardous waste) plus fuel in the captive power plant. This is the share addressable by alternative-fuel substitution and thermal-efficiency improvements.

The split matters because the decarbonisation levers are entirely different:

• For process emissions: clinker substitution (raising the share of supplementary cementitious materials in finished cement — fly ash, blast-furnace slag, calcined clay / pozzolana) and, prospectively, carbon capture from kiln flue gas.
• For combustion emissions: rising Alternative Fuel Ratio (AFR) / Thermal Substitution Rate (TSR), kiln thermal efficiency, transition to lower-carbon fuels.

Most Indian listed cement majors report the split in their voluntary sustainability disclosures even though the SEBI BRSR Format does not prescribe the bifurcation. The methodology commonly applied is the GCCA / WBCSD CSI Cement CO₂ and Energy Protocol, which is the global sector-standard accounting reference.

Captive Power Plants (CPPs) and Waste Heat Recovery

Integrated cement plants commonly operate captive power generation to ensure reliability:

• Owned + operated CPP — fuel combusted in the CPP is Scope 1; electricity generated is on-site and is not Scope 2.
• Group-subsidiary CPP — where a separate group entity owns the CPP and the cement entity purchases electricity under a PPA, emissions are typically Scope 2 (location-based or market-based per the GHG Protocol Scope 2 Guidance).
• Waste Heat Recovery System (WHRS) — recovers exhaust heat from the kiln preheater and clinker cooler to generate electricity via a steam Rankine cycle; produces zero additional Scope 1 fuel combustion and reduces purchased-grid Scope 2. WHRS capacity disclosure is commonly featured in Principle 6 narrative.
• Renewable PPAs — increasing share of grid + behind-the-meter solar / wind purchased under PPAs; reported per the GHG Protocol Scope 2 Guidance market-based method where contractual instruments support the claim.

Alternative Fuel Ratio / Thermal Substitution Rate

The Alternative Fuel Ratio (AFR) — equivalently called Thermal Substitution Rate (TSR) — is the share of kiln thermal energy delivered by alternative fuels rather than fossil fuels (coal + petcoke). Common alternative fuels in Indian cement kilns:

• Refuse-Derived Fuel (RDF) processed from municipal solid waste
• Industrial / hazardous waste co-processing (used solvents, plastics, tyres, leather residue, paint sludge)
• Biomass (agricultural residue, rice husk)

Indian listed cement majors typically report AFR / TSR voluntarily in their sustainability disclosures and in narrative under Principle 6 of BRSR. The sector trajectory is upward — Indian cement AFR averages have risen materially over the past decade, though the global benchmark (especially European cement) remains substantially higher.

Clinker-to-cement ratio

The single largest lever for reducing cement’s GHG intensity (Scope 1 + 2 per tonne cement) is reducing the share of clinker in finished cement — because clinker carries the calcination process emissions. Indian cement is sold in several blended grades regulated by BIS standards:

• OPC (IS 269) — Ordinary Portland Cement, ~95% clinker, highest intensity per tonne.
• PPC (IS 1489) — Portland Pozzolana Cement, ~65–80% clinker + ~15–35% fly ash; reduced intensity.
• PSC (IS 455) — Portland Slag Cement, ~30–70% clinker + ~30–70% blast-furnace slag.
• Composite cement (IS 16415) — limestone + slag + fly ash blends.

Most Indian listed cement majors disclose the clinker-to-cement ratio (or its inverse, blended-cement share) under Principle 6 because it is the single most informative sectoral decarbonisation metric. The trajectory has been improving as PPC and PSC have grown share against OPC.

Waste co-processing in cement kilns

Cement kilns operate at very high temperatures (clinker formation typically around 1450°C) with long residence time — conditions that allow complete destruction of organic compounds. This makes cement kilns a regulated outlet for co-processing hazardous and non-hazardous waste streams (RDF from MSW, used tyres, agricultural residue, paint sludge, certain hazardous wastes under Schedule I of the Hazardous Wastes Rules). Co-processing serves two functions simultaneously — alternative-fuel substitution (reducing combustion Scope 1) and waste-management service to the regional industrial / municipal ecosystem. This dual role is commonly featured in Principle 6 narrative under both energy / emissions and waste-management framings.

Water positive claims and water intensity

Water Withdrawal Intensity (methodology) is typically material for cement entities — driven by kiln-clinker cooling, equipment cooling, mine-area dust suppression, and CPP cooling. Common features:

• Mine-area water use — dust suppression on haul roads, sometimes substantial; reported under the operational boundary that includes captive mines.
• CPP cooling — substantial for thermal-power CPP operations; substantially lower for WHRS.
• ‘Water positive’ certifications — several Indian cement majors publish water-positive claims (independently certified, often by CII or independent assessors). These are voluntary disclosures, not BRSR-mandated. The methodology behind the claim — what counts as ‘replenishment’, what watershed boundary applies, how community-rainwater-harvesting structures are measured — should be specified for the disclosure to carry weight.

EU CBAM exposure for cement exporters

Cement is one of the six initial sectors in scope for the EU Carbon Border Adjustment Mechanism under Regulation (EU) 2023/956, alongside iron and steel, aluminium, fertilisers, hydrogen, and electricity.

• Transitional period — 1 October 2023 to 31 December 2025 — Indian exporters of in-scope cement products (cement clinker, white Portland cement, other Portland cement, aluminous cement, other hydraulic cements) must provide embedded-emissions data on a quarterly basis to their EU importers, who file CBAM reports per Implementing Regulation (EU) 2023/1773. No financial obligation in the transitional phase.
• Definitive regime — from 1 January 2026 — EU importers must purchase CBAM certificates against embedded emissions, priced at the weekly EU ETS auction rate net of free allocations to EU domestic producers. Free allocation to EU producers is phased out gradually through 2034, raising the effective CBAM price progressively.
• Embedded-emissions methodology — CBAM-specific product-level boundary and verification requirements per the Implementing Regulation; the methodology overlaps with but does not equal BRSR Core enterprise-level Scope 1 + 2 disclosure. Indian exporters should derive both disclosures from a common carbon-accounting infrastructure to maintain consistency.

For Indian cement exporters to the EU, CBAM is a present-day compliance requirement; Batchwise coordinates EU CBAM Declaration preparation through partner CA firms.

Common Scope 3 categories

Scope 3 categories commonly observed as material in published cement submissions:

• Category 1 (Purchased goods and services) — supplementary cementitious materials (fly ash, slag, synthetic gypsum), packaging bags, refractory materials. Cat 1 share rises as the clinker-to-cement ratio falls (more SCM purchased per tonne cement).
• Category 4 (Upstream transportation and distribution) — limestone from captive mines, coal / petcoke from ports, fly ash from thermal-power-plant sources, slag from steel-plant sources.
• Category 9 (Downstream transportation and distribution) — bulk cement to RMC and major-project sites, bagged cement to dealer networks, predominantly road-based.
• Category 11 (Use of sold products) — generally immaterial for cement; the product does not emit GHGs during use (unlike fossil fuels or vehicles).
• Category 12 (End-of-life treatment of sold products) — generally immaterial given concrete’s long service life (often >50 years) and the absence of significant end-of-life GHG release.

Comprehensive Scope 3 disclosure historically sat in Principle 6 Leadership (voluntary), but per the SEBI BRSR Core circular dated 12 July 2023, Scope 3 GHG disclosure is required from the top 250 listed entities on a comply-or-explain basis from FY 2024–25, with assurance phased from FY 2025–26 on the same basis. See the Value Chain Disclosure glossary entry for scoping mechanics and the Scope 3 glossary entry.

Section A patterns specific to cement

Several distinctive patterns:

1. Plant and mine inventory — Section A operations disclosure typically includes integrated plants, standalone grinding units, RMC plants, and captive limestone (and sometimes fly-ash / coal) mines. Many entities supply the full plant and mine register as a Section A annexure given the scale.
2. Workforce stratification — multi-tier: corporate, plant management, permanent operators (kiln, packing, electrical, mechanical), captive-mine workforce, contract operators (often material in loading / unloading, packing, and mine operations), and outsourced security / housekeeping. Mining workforce typically dominates the entity’s lost-time-injury and fatality statistics — see the BRSR Section A Pre-fill Workflow for the mapping table approach.
3. Logistics subsidiaries — many cement groups operate captive logistics subsidiaries (rail siding operators, trucking subsidiaries, port-handling subsidiaries). Where the subsidiary is operationally controlled and consolidated, its emissions are Scope 1 + 2 of the cement group; where it is a separate counterparty, emissions land in Scope 3 Cat 4 / Cat 9.
4. Subsidiary / group structure — listed cement groups commonly have an RMC subsidiary, a captive logistics subsidiary, an international subsidiary (overseas cement / clinker operations), and sometimes a separately listed captive power subsidiary. Boundary basis (operational vs financial vs equity-share control) should be applied consistently with Ind AS 110 consolidation and the SEBI December 2024 Industry Standards methodology guidance.
5. CSR spend — Section 135 of the Companies Act 2013 typically applies; cement CSR commonly anchors on community infrastructure, water / sanitation, livelihood enhancement, and education in plant- and mine-proximate communities.

How Batchwise fits

Batchwise coordinates BRSR Core Assurance for listed cement entities through its partner CA firm network. The BRSR Core sign-off is delivered under partner CA firm letterhead and DSC; Batchwise handles the operational layer — buyer onboarding, evidence ingestion via the document portal, partner CA firm assignment, status tracking, and a 72-hour SLA on the coordinated end-to-end.

For cement entities exporting to the EU, Batchwise also coordinates EU CBAM Declaration preparation — the quarterly embedded-emissions report (transitional phase) and the definitive-period CBAM certificate workflow from 2026 onward — through the same partner-CA-firm model. For standalone Scope 1 + 2 GHG verification (often required by global parent reporting or by enterprise customers), ISAE 3410 is coordinated under the same model.

See also: Document and Evidence Requirements for the artifacts the assurance provider expects, GHG Protocol glossary entry for the underlying accounting framework, and Materiality Assessment Walkthrough for the upstream scoping step that drives which Core attributes the engagement focuses on.