A short answer, followed by the source guide and related questions.
No. CBAM embedded-emissions calculations must follow the applicable EU method and production boundary.
This answer is taken from Draft Carbon Calculation Record. Use the full guide for scope, assumptions and cited sources.
Use measured surface area, temperature and operating hours to calculate heat loss from boilers, kilns, heat exchangers, valves and pipework. Inzonex supplies removable modular insulation for equipment that requires maintenance access.
Do not add a calculated reduction to an emissions report until the reporting boundary, factor, implementation date and verification method have been approved.