Audit-Grade Methodology · ISO 14067 & EU CBAM

TISEE Two-Tier Mass Balance Allocation Model 2.0

Technical specification for calculating specific embedded emissions in continuous mesh-belt heat treatment furnaces. Fully compliant with Regulation (EU) 2023/1773 Annex IV and ISO 14067.

David Ishayahu (Wang Junwei)·TISEE Data Science & LegalTech Research Lab·Published: July 27, 2026

Executive Summary

In continuous industrial manufacturing—specifically Southern Taiwan's fastener cluster supplying 12%+ of EU industrial fasteners—subcontracted continuous heat-treatment furnaces operate 24/7 with mixed product batches. Under EU Regulation (EU) 2023/1773 Annex IV, relying on default country emission factors results in up to a 2.4x penalty markup. TISEE Data Science & LegalTech Research Lab established the Two-Tier Mass Balance Allocation Model 2.0 to provide verifiable, audit-grade carbon intensity metrics for overseas importers and EU competent authorities (NCAs).

1. Mathematical Model Specification

Under EU CBAM rules, scrap steel credits cannot be deducted directly as a negative carbon line item. Model 2.0 converts scrap yield loss into a physical mass allocation ratio while incorporating Scope 3 steel wire precursors:

Specific Embedded Emissions Formula (tCO₂e/t)ISO 14067 ✕ EU CBAM Compliant
SEE_fastener = [ SEE_precursor × (M_input / M_good) ] + [ (E_direct_fuel + E_indirect_power) / M_good ]
Tier 1: Precursor & Yield Allocation

SEE_precursor represents Scope 3 wire rod carbon intensity from primary mills (70%–85% of total SEE). M_input / M_good scales emissions by the yield loss ratio, complying with EU scrap restrictions.

Tier 2: Continuous Furnace Energy

Processing natural gas (E_direct_fuel) and electricity (E_indirect_power) are allocated dynamically by batch residence time × charge mass.

2. Continuous Mesh-Belt Furnace Dynamic Allocation

Continuous annealing and quenching furnaces operate without stopping between batches. To allocate gas and power without artificial lump-sum assumptions, Tier 2 applies a weighted time-mass stream formula:

Batch Energy Stream Allocation Equation

E_batch_fuel = E_total_furnace_fuel × [ (T_residence × M_batch_input) / ∑ (T_i × M_i) ]

Where T_residence is the verified belt speed duration in hours for the specific production lot, and M_batch_input is the gross charge weight in metric tons.

3. Comparative Audit Compliance Analysis

DimensionGeneric Allocation (Model 1.0)TISEE Model 2.0EU Audit Advantage
Scrap TreatmentDirect deduction (- Scrap Credit)Yield Mass Ratio (M_input / M_good)Eliminates rejection risk under EU 2023/1773.
Precursor Scope 3Omitted or unsegmentedExplicit SEE_precursor (70%-85%)Prevents under-reporting red flags by EU NCAs.
Continuous FurnaceFlat annual average per tonBatch Time × Mass Stream WeightingResolves energy fairness across different screw sizes.

4. Integration with EU CBAM Article 9 Carbon Fee Offsets

Once Model 2.0 determines specific embedded emissions, TISEE provides audit-trail mapping for Taiwan MOENV carbon fee receipts (NT$ 300/tCO2e baseline). Under Regulation (EU) 2023/956 Article 9(1), authorized declatants claim equivalent EUR deductions on surrendered CBAM certificates without double taxation.

1. Verified Mill Test Reports (MTR)

Primary steel Scope 3 precursor data matched directly against China Steel Corporation (CSC) or Feng Hsin Steel certificates.

2. Subcontracting Sub-Meter Audits

IoT sub-metering on Tier-2 heat-treatment and electroplating lines ensures zero reliance on unverified manual logs.

Custom Technical Advisory

Request Audit-Grade Mass Balance Verification for Your Supply Chain

Consult TISEE Data Science & LegalTech Research Lab to implement Two-Tier Mass Balance Allocation Model 2.0 for your Taiwanese fastener exports.