This guide extracts the contents of the emissions methodology annexes and outlines the key implications of relevant clauses for producers of CBAM goods.
ANNEX I - Definitions, functional unit and system boundaries
1. DEFINITIONS
For the purpose of this Annex and of Annexes II to VII the following definitions apply:
(1) ‘uncertainty’ means a parameter, associated with the result of the determination of a quantity, that characterises the dispersion of the values that could reasonably be attributed to the particular quantity, including the effects of systematic as well as of random factors, expressed in per cent, and describes a confidence interval around the mean value comprising 95% of inferred values taking into account any asymmetry of the distribution of values;
(2) ‘combustion emissions’ means greenhouse gas emissions occurring during the exothermic reaction of a fuel with oxygen;
(3) ‘emission factor’ means the average emission rate of a greenhouse gas relative to the activity data of a source stream assuming complete oxidation for combustion and complete conversion for all other chemical reactions;
(4) ‘oxidation factor’ means the ratio of carbon oxidised to CO2 as a consequence of combustion to the total carbon contained in the fuel, expressed as a fraction, considering carbon monoxide (CO) emitted to the atmosphere as the molar equivalent amount of carbon dioxide (CO2);
(5) ‘conversion factor’ means the ratio of carbon emitted as CO2 to the total carbon contained in the source stream before the emitting process takes place, expressed as a fraction, considering CO emitted to the atmosphere as the molar equivalent amount of CO2;
(6) ‘accuracy’ means the closeness of the agreement between the result of a measurement and the true value of the particular quantity or a reference value determined empirically using internationally accepted and traceable calibration materials and standard methods, taking into account both random and systematic factors;
(7) ‘calibration’ means the set of operations, which establishes, under specified conditions, the relations between values indicated by a measuring instrument or measuring system, or values represented by a material measure or a reference material and the corresponding values of a quantity realised by a reference standard;
(8) ‘conservative’ means that a set of assumptions is defined in order to ensure that no under-estimation of reported emissions or over-estimation of production of heat, electricity or goods occurs;
(9) ‘biomass’ means biomass as defined in Article 2, point (24) of Directive (EU) 2018/20011; it includes bioliquids and biofuels as defined in Article 2, point (32) and (33), biomass fuels as defined in Article 2, point (27) and biogas as defined in Article 2 point (28) of Directive 2018/2001;
(10) ‘waste’ means any substance or object which the holder discards or intends or is required to discard, excluding substances that have been intentionally modified or contaminated in order to meet this definition;
(11) ‘residue’ means a substance that is not the end product that a production process directly seeks to produce; it is not a primary aim of the production process and the process has not been deliberately modified to produce it;
(12) ‘agricultural, aquaculture, fisheries and forestry residues’ means residues that are directly generated by agriculture, aquaculture, fisheries and forestry and that do not include residues from related industries or processing;
(13) ‘legal metrological control’ means the control exercised by a public authority or regulator of the measurement tasks intended for the field of application of a measuring instrument, for reasons of public interest, public health, public safety, public order, protection of the environment, the levying of taxes and duties, the protection of consumers and fair trading;
(14) ‘data flow activities’ mean activities related to the acquisition, processing and handling of data that are needed to draft an emissions report from primary source data;
(15) ‘net calorific value’ (NCV) means the specific amount of energy released as heat when a fuel or material undergoes complete combustion with oxygen under standard conditions, less the heat of vaporisation of any water formed;
(16) ‘process emissions’ means greenhouse gas emissions other than combustion emissions occurring as a result of intentional and unintentional reactions between substances or their transformation, for a primary purpose other than the generation of heat, including from the following processes:
(a) the chemical, electrolytic or pyrometallurgical reduction of metal compounds in ores, concentrates and secondary materials;
(b) the removal of impurities from metals and metal compounds;
(c) the decomposition of carbonates, including those used for flue gas cleaning;
(d) chemical syntheses of products and intermediate products where the carbon bearing material participates in the reaction;
(e) the use of carbon containing additives or raw materials;
(f) the chemical or electrolytic reduction of metalloid oxides or non-metal oxides such as silicon oxides and phosphates.
(17) ‘batch’ means an amount of fuel or material representatively sampled and characterised, and transferred as one shipment or continuously over a specific period of time;
(18) ‘mixed material’ means a material which contains both biomass and fossil carbon;
(19) ‘preliminary emission factor’ means the assumed total emission factor of a fuel or material based on the carbon content of its biomass fraction and its fossil fraction before multiplying it by the fossil fraction to produce the emission factor;
(20) ‘fossil fraction’ means the ratio of fossil carbon to the total carbon content of a fuel or material, expressed as a fraction;
(21) ‘biomass fraction’ means the ratio of carbon stemming from biomass to the total carbon content of a fuel or material, expressed as a fraction;
(22) ‘continuous emission measurement’ means a set of operations having the objective of determining the value of a quantity by means of periodic measurements, applying either measurements in the stack or extractive procedures with a measuring instrument located close to the stack, whilst excluding measurement methodologies based on the collection of individual samples from the stack;
(23) ‘inherent CO2’ means CO2 which is part of a source stream;
(24) ‘fossil carbon’ means inorganic and organic carbon that is not biomass;
(25) ‘measurement point’ means the emission source for which continuous emission measurement systems (CEMS) are used for emission measurement, or the cross-section of a pipeline system for which the CO2 flow is determined using continuous measurement systems;
(26) ‘fugitive emissions’ means irregular or unintended emissions from sources that are not localised, or too diverse or too small to be monitored individually;
(27) ‘standard conditions’ means temperature of 273,15 K and pressure conditions of 101 325 Pa defining normal cubic metres (Nm3);
(28) ‘proxy data’ means annual values which are empirically substantiated or derived from accepted sources and which an operator uses to substitute a data set for the purpose of ensuring complete reporting;
(29) ‘measurable heat’ means a net heat flow transported through identifiable pipelines or ducts using a heat transfer medium, such as, in particular, steam, hot air, water, oil, liquid metals and salts, for which a heat meter is or could be installed;
(30) ‘heat meter’ means a thermal energy meter or any other device to measure and record the amount of thermal energy produced based upon flow volumes and temperatures;
(31) ‘non-measurable heat’ means all heat other than measurable heat;
(32) ‘waste gas’ means a gas containing incompletely oxidised carbon in a gaseous state under standard conditions which is a result of any of the processes listed in point (16);
(33) ‘multifunctional process’ means a process that delivers multiple outputs or whose outputs feed into several production processes;
(34) ‘co-product’ means any of two or more products resulting from the same production process;
(35) ‘non-CBAM good’ means any good produced in the installation that is not included in Annex I to Regulation (EU) 2023/956;
(36) ‘data set’ means one type of data, either at installation level or production process level as relevant in the circumstances, as any of the following:
(a) the amount of fuels or materials consumed or produced by a production process as relevant for the calculation-based methodology, expressed in terajoules, mass in tonnes, or for gases as volume in normal cubic metres, as appropriate, including for waste gases;
(b) a calculation factor;
(c) net quantity of measurable heat, and the relevant parameters required for determining this quantity, in particular:
– mass flow of heat transfer medium, and
– enthalpy of transmitted and returned heat transfer medium, as specified by composition, temperature, pressure and saturation;
(d) quantities of non-measurable heat, specified by the relevant quantities of fuels used for producing the heat, and the NCV of the fuel mix;
(e) quantities of electricity;
(f) quantities of CO2 transferred between installations;
(g) quantities of precursors received from outside the production process, and their relevant parameters, such as country of origin, used production route, specific direct and indirect emissions;
(37) ‘minimum requirements’ means monitoring methods using the minimum efforts allowed for determining data in order to result in emission data acceptable for the purpose of Regulation (EU) 2023/956;
(38) ‘recommended improvements’ means monitoring methods which are proven means to ensure that data are more accurate or less prone to mistakes than by mere application of minimum requirements;
(39) ‘control system’ means the operator’s risk assessment and entire set of control activities, including the continuous management thereof, that an operator has established, documented, implemented and maintained pursuant to point A.2. of Annex II.
3. FUNCTIONAL UNIT AND SYSTEM BOUNDARIES
3.1 Cross-sectoral rules
Specific embedded emissions shall be calculated as the emissions of the production process and, for complex goods, the embedded emissions of the precursors to produce the functional unit of the good during the reporting period.
The system boundaries are defined per aggregated goods categories and cover the direct emissions, the indirect emissions from electricity consumption where relevant under Regulation (EU) 2023/956, emitted by all processes directly or indirectly linked to the production processes, and the embedded emissions of precursors, independently of whether these precursors are produced in the installation or acquired from a different installation. In addition to these general rules, the specific details of each aggregated goods category are set out in points 3.2 to 3.19. Any CBAM goods produced by means of a production route not listed in points 3.2. to 3.19. is subject to the cross-sectoral rules described in this point, and to the sector-specific rules if the production route is a combination of the production routes listed in in points 3.2. to 3.19.
The purchase and maintenance of infrastructure and equipment are excluded from the system boundaries.
When the production process of complex goods listed in Annex II to Regulation (EU) 2023/956 includes one or more precursors not listed in that Annex, the indirect emissions of those precursors will be included in the calculation of the embedded emissions of the complex goods. When the production process of complex goods not listed in that Annex includes one or more precursors listed in that Annex, the indirect emissions of these precursors will not be included in the calculation of the embedded emissions of the complex goods.
3.2 Calcined clay
3.2.1. Special provisions
None
3.2.2. System boundary
For calcined clay, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes, such as raw material preparation, mixing, drying, and calcining, and flue gas cleaning;
–bCO2 emissions from the combustion of fuels as well as from raw materials, where relevant.
3.3 Cement clinker
3.3.1 Special provisions
No distinction shall be made between grey and white cement clinker.
3.3.2 System boundary
For cement clinker, direct emissions monitoring take into account:
– calcination of limestone and other carbonates in the raw materials, conventional fossil kiln fuels, alternative fossil-based kiln fuels and raw materials, biomass kiln fuels (such as waste-derived fuels), non-kiln fuels, non-carbonate carbon content in raw materials, or alternative raw materials such as fly ash used in the raw meal in the kiln and raw materials used for flue gas scrubbing;
– the additional provisions of point B.9.2. of Annex II.
3.4 Cement
3.4.1 Special provisions
None.
3.4.2 System boundary
For cement, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes, where relevant for drying of materials.
3.5 Aluminous cement
3.5.1 Special provisions
None.
3.5.2 System boundary
For aluminous cement, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes where fuel is combusted;
– process emissions from carbonates in raw materials, if applicable, and flue gas cleaning.
3.6 Hydrogen
3.6.1 Special provisions
Only the production of pure hydrogen or mixtures of hydrogen with nitrogen usable in ammonia production shall be considered. Not covered are the consumption of synthesis gas or of hydrogen as precursor within refineries or organic chemical installations, where hydrogen is exclusively used within those plants and not used for the production of goods listed in Annex I to Regulation (EU) 2023/956.
3.6.2 System boundary
3.6.2.1 Steam reforming and partial oxidation
For those production routes, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to hydrogen production and the separation of hydrogen and carbon monoxide, and flue gas cleaning;
– all fuels used in the hydrogen production process irrespective of their energetic or non-energetic use, and fuels used for other combustion processes including for the purpose of producing hot water or steam.
3.6.2.2 Steam cracking
For that production route, direct emissions monitoring shall take into account:
– all processes directly linked to hydrogen production;
– all processes directly or indirectly linked to the production processes, and from flue gas cleaning.
3.7 Ammonia
3.7.1 Special provisions
None
3.7.2 System boundary
3.7.2.1 Haber-Bosch process with steam reforming of natural gas or biogas
For that production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes, and from flue gas cleaning;
– all fuels are to be monitored, irrespective of whether used as energetic or non-energetic input;
– where biogas is used, the provisions of point B.3.3. of Annex II
3.7.2.2 Haber-Bosch process with gasification of coal or other fuels
That production route applies where hydrogen is produced by gasification of coal, heavy refinery fuels or other fossil feedstock. Input materials may include biomass, for which the provisions of point B.3.3. of Annex II shall be taken into account.
For that production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes, and from flue gas cleaning;
– each fuel input shall be monitored as one fuel stream, irrespective of whether it is used as energetic or non-energetic input.
3.8 Nitric acid
3.8.1 Special provisions
None.
3.8.2 System boundary
For nitric acid, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes, and from flue gas cleaning;
– all sources emitting N2O from the production process, including unabated and abated emissions. Any N2O emissions from the combustion of fuels are excluded from monitoring.
3.9 Urea
3.9.1 Special provisions
None.
3.9.2 System boundary
For urea, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes, and from flue gas cleaning;
– where CO2 is received from another installation as process input, the CO2 received shall be considered an emission, if not already counted as emission of the installation where the CO2 was produced.
3.10 Mixed fertilizers
3.10.1 Special provisions
This point applies to the production of all kinds of nitrogen containing fertilizers, including ammonium nitrate, calcium ammonium nitrate, ammonium sulphate, ammonium phosphates, urea ammonium nitrate solutions, as well as nitrogen-phosphorus (NP), nitrogen-potassium (NK) and nitrogen-phosphorus-potassium (NPK) fertilizers. All kinds of operations are included such as mixing, neutralisation, granulation, prilling, irrespective of whether only physical mixing or chemical reactions take place.
The amounts of different nitrogen compounds contained in the final product shall be recorded in accordance with Regulation (EU) 2019/1009(*):
– content of N as ammonium (NH4+);
– content of N as nitrate (NO3–);
– content of N as Urea;
– content of N in other (organic) forms.
(*) Regulation (EU) 2019/1009 of the European Parliament and of the Council of 5 June 2019 laying down rules on the making available on the market of EU fertilising products and amending Regulations (EC) No 1069/2009 and (EC) No 1107/2009 and repealing Regulation (EC) No 2003/2003 (OJ L 170, 25.6.2019, p. 1)
3.10.2 System boundary
For mixed fertilisers, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes, such as driers and for heating input materials, and from flue gas cleaning.
3.11 Sintered Ore
3.11.1 Special provisions
This aggregated goods category includes all kinds of iron ore pellet production (for sale of pellets as well as for direct use in the same installation) and sinter production. To the extent covered by CN code 2601 12 00, also iron ores used as precursors for ferro-chromium (FeCr), ferro-manganese (FeMn) or ferro-nickel (FeNi) may be covered.
3.11.2 System boundary
For sintered ore, direct emissions monitoring shall encompass:
– all processes emitting CO2 from process materials such as limestone and other carbonates or carbonate ores;
– all processes emitting CO2 from all fuels including coke, waste gases such as coke oven gas, blast furnace gas or converter gas; directly or indirectly linked to the production process, and materials used for flue gas cleaning.
3.12 FeMn (Ferro-Manganese), FeCr (Ferro-Chromium) and FeNi (Ferro-Nickel)
3.12.1 Special provisions
This process covers only the production of the alloys identified under CN codes 7202 1, 7202 4 and 7202 6. Other iron materials with significant alloy content such as spiegeleisen are not covered. NPI (nickel pig iron) is included if the nickel content is greater than 10%.
Where waste gases or other flue gases are emitted without abatement, CO contained in the waste gas shall be considered as the molar equivalent of CO2 emissions.
3.12.2 System boundary
For FeMn, FeCr and FeNi, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes emitting CO2 emissions caused by fuel inputs, irrespective of whether they are used for energetic or non-energetic use;
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from process inputs such as limestone and from flue gas cleaning;
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from the consumption of electrodes or electrode pastes;
– carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with point B.3.2 of Annex II.
3.13 Pig Iron
3.13.1 Special provisions
This aggregated goods category includes non-alloyed pig iron from blast furnaces as well as alloy-containing pig irons (e.g., spiegeleisen), irrespective of the physical form (e.g. ingots, granules). NPI (nickel pig iron) is included if the nickel content is lower than 10%. In integrated steel plants, liquid pig iron (“hot metal”) directly charged to the oxygen converter is the product which separates the production process for pig iron from the production process of crude steel. Where the installation does not sell or transfer pig iron to other installations, a joint production process including crude steel can be established making subject to the rules of Article 4.
3.13.2 System boundary
3.13.2.1 Blast furnace route
For that production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes emitting CO2 from fuels and reducing agents such as coke, coke dust, coal, fuel oils, plastic wastes, natural gas, wood wastes, charcoal, as well as from waste gases such as coke oven gas, blast furnace gas or converter gas;
– where biomass is used, the provisions of point B.3.3 of Annex II shall be taken into account;
– all processes directly or indirectly linked to the production processes emitting CO2 from process materials such as limestone, magnesite, and other carbonates, carbonate ores; materials for flue gas cleaning;
– carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with point B.3.2 of Annex II.
3.13.2.2 Smelting reduction
For this production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes emitting CO2 from fuels and reducing agents such as coke, coke dust, coal, fuel oils, plastic wastes, natural gas, wood wastes, charcoal, waste gases from the process or converter gas;
– where biomass is used, the provisions of point B.3.3 of Annex II shall be taken into account;
– all processes directly or indirectly linked to the production processes emitting CO2 from process materials such as limestone, magnesite, and other carbonates, carbonate ores; materials for flue gas cleaning;
– carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with point B.3.2 of Annex II.
3.14 DRI (Direct Reduced Iron)
3.14.1 Special provisions
There is only one production route defined, although different technologies may use different qualities of ores, which may require pelletisation or sintering, and different reducing agents (natural gas, diverse fossil fuels or biomass, hydrogen). Therefore, precursors sintered ore or hydrogen may be relevant. As products, iron sponge, hot briquetted iron (HBI) or other forms of direct reduced iron may be relevant, including DRI which is immediately fed to electric arc furnaces or other downstream processes.
Where the installation does not sell or transfer DRI to other installations, a joint production process including steel can be established making subject to the rules of Article 4.
3.14.2 System boundary
For that production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes emitting CO2 from fuels and reducing agents such as coal, natural gas, fuel oils, waste gases from the process or converter gas, etc;
– where biogas or other forms of biomass are used, the provisions of point B.3.3 of Annex II shall be taken into account;
– all processes directly or indirectly linked to the production processes emitting CO2 from process materials such as limestone, magnesite, and other carbonates, carbonate ores, materials for flue gas cleaning;
– carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with point B.3.2 of Annex III.
3.15 Crude steel
3.15.1 Special provisions
The system boundary shall cover all necessary activities and units for obtaining crude steel:
– if the process starts from hot metal (liquid pig iron), the system boundary shall include the basic oxygen converter, vacuum degassing, secondary metallurgy, argon oxygen decarburisation / vacuum oxygen decarburisation, continuous casting or ingot casting, where relevant hot-rolling or forging, and all necessary auxiliary activities such as transfers, re-heating, and flue gas cleaning;
– if the process uses an electric arc furnace, the system boundary shall include all relevant activities and units such as the electric arc furnace itself, secondary metallurgy, vacuum degassing, argon oxygen decarburisation / vacuum oxygen decarburisation, continuous casting or ingot casting, where relevant hot-rolling or forging, and all necessary auxiliary activities such as transfers, heating of raw materials and equipment, re-heating, and flue gas cleaning;
– only primary hot-rolling and rough shaping by forging to obtain the semi-finished products under CN codes 7207, 7218 and 7224 are included in this aggregated goods category. All other rolling and forging processes are included in the aggregated goods category “iron or steel products”.
3.15.2 System boundary
3.15.2.1 Basic oxygen steelmaking
For that production route, direct emissions monitoring shall encompass:
– all processes directly or indirectly linked to the production processes emitting CO2 from fuels such as coal, natural gas, fuel oils, waste gases such as blast furnace gas, coke oven gas or converter gas;
– all processes directly or indirectly linked to the production processes emitting CO2 from process materials such as limestone, magnesite, and other carbonates, carbonate ores; materials for flue gas cleaning;
– carbon entering the process in scrap, alloys, graphite etc. and carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with Point B.3.2 of Annex III.
3.15.2.2 Electric arc furnace
For that production route, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting CO2 from fuels such as coal, natural gas, fuel oils, as well as from waste gases such as blast furnace gas, coke oven gas or converter gas;
– all processes directly or indirectly linked to the production processes emitting CO2 from the consumption of electrodes and electrode pastes;
– all processes directly or indirectly linked to the production processes emitting CO2 from process materials such as limestone, magnesite, and other carbonates, carbonate ores; materials for flue gas cleaning;
– carbon entering the process, e.g. in the form of scrap, alloys and graphite, and carbon remaining in the product or in slags or wastes is taken into account by using a mass balance method in accordance with Point B.3.2 of Annex III.
3.16 Iron or steel products
3.16.1 Special provisions
None
3.16.2 System boundary
For iron or steel products, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from combustion of fuels and process emissions from flue gas treatment, including re-heating, re-melting, casting, hot rolling, cold rolling, forging, annealing, coating, galvanizing, wire drawing, pickling and excluding the following processes: plating, cutting, welding and finishing of iron or steel products.
3.17 Unwrought aluminium
3.17.1 Special provisions
This aggregated goods category includes non-alloyed as well as alloyed aluminium, in physical form typical for unwrought metals, such as ingots, slabs, billets or granules. In integrated aluminium plants, liquid aluminium directly charged to the production of aluminium products is included, too.
3.17.2 System boundary
3.17.2.1 Primary (electrolytic) smelting
For that production route, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from the consumption of electrodes or electrode pastes;
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from any fuels used (e.g. for drying and pre-heating of raw materials, heating of electrolysis cells, heating required for casting);
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from any flue gas treatment, from soda ash or limestone if relevant;
– perfluorocarbon emissions caused by anode effects monitored in accordance with Point B.7 of Annex II.
3.17.2.2 Secondary melting (recycling)
Secondary melting (recycling) of aluminium uses aluminium scrap as main input. However, where unwrought aluminium from other sources is added, it is treated like a precursor.
For that production route, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from any fuels used for drying and pre-heating of raw materials, used in melting furnaces, in pre-treatment of scrap such as de-coating and de-oiling, and combustion of the related residues, and fuels required for casting of ingots, billets or slabs;
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from any fuels used in associated activities such as treatment of skimmings and slag recovery;
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from any flue gas treatment, from soda ash or limestone if relevant.
3.18 Aluminium products
3.18.1 Special provisions
None
3.18.2 System boundary
For aluminium products, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting CO2 emissions from combustion of fuels and process emissions from flue gas treatment, excluding the following processes: cutting, welding and finishing of aluminium
products.
3.19 Electricity
3.19.1 Special provisions
The emission factor for electricity shall be determined in accordance with Point D.2 of Annex III.
3.19.2 System boundary
For electricity, direct emissions monitoring shall take into account:
– all processes directly or indirectly linked to the production processes emitting combustion emissions and process emissions from flue gas treatment.