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CBAM for steel exporters
For steel, only direct emissions count. EU default values for hot-rolled flat steel (CN 7208) range from 0.140 to 8.230 tonnes of CO₂e per tonne across 32 countries, and your customer pays for 2.5% of the embedded emissions in 2026, rising to 100% by 2034.
If you ship steel to the European Union, your customer now pays for the carbon embedded in it — and pays more when you send no data. This is what the rules ask of you.
Compare with the EU default free →
What is covered
CN chapters 72 and 73 — from crude steel and pig iron to screws, tubes and structures. The code on your export invoice decides it, not the name of the product.
Which emissions count
In the definitive period, direct emissions only. That means fuels burned in fixed equipment at your site, process emissions from materials such as carbonates and electrodes, and the emissions embedded in the CBAM material you purchased. Electricity is reported but not counted — sintered ore is the single exception.
COUNTS
- Fuels burned in fixed equipment at your site
- Process emissions — carbonates, electrodes, reductants
- The carbon in scrap and alloys you charge
- Emissions embedded in the CBAM steel you bought and fed in
REPORTED, BUT DOES NOT COUNT
- Electricity you consume — including an electric arc furnace, where it is the main energy input. Sintered ore is the single exception
- Scrap and returned product, on the output side
(your direct emissions + emissions of the material you bought) ÷ saleable output= tonnes of CO₂e per tonne of product. Offcuts and losses stay on the input side: 100 tonnes of rod in, 80 tonnes of screws out — the figure is 100.
- Electric arc furnace — electricity is the main energy input, but it does not count towards your CBAM figure. Your electrodes, natural gas and the carbon in scrap and alloys do.
- Blast furnace route — coke and reductants dominate; a mass balance is required.
- Fabricators who buy rod, coil or billet and make screws, pipes or sections: the bought steel carries its own emissions into your product, and that is usually most of your total.
What the number looks like
The figure is tonnes of CO₂e per tonne of product: your own direct emissions plus the emissions of the material you bought, divided by your saleable output. Scrap and returned product are excluded from output; offcuts and losses stay in the input side.
What it costs your customer
Certificate cost is tonnes × your value × the EU carbon price × the phase-in factor, which is 2.5% in 2026 and rises to 100% by 2034. With no data from you, the country default plus mark-up is used instead. The gap between the two is what you are negotiating over.
Compare against your country's default →
Verification
From 2026, actual values must be checked by an accredited verifier before they can be used. Plan for it, and until then describe your figures honestly as verification-ready, not verified.
Questions exporters ask
Which products does CBAM cover?
CBAM covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, identified by CN code rather than by product name.
For metals, iron and steel sit mainly in CN chapters 72 and 73 and aluminium in chapter 76, from unwrought metal to finished items such as screws, tubes and structures. Check the code on your export invoice against Annex I of the Regulation.
Source: Regulation (EU) 2023/956, Annex I
How is the CBAM emissions value per tonne calculated?
It is your installation's direct emissions attributed to the product, plus the emissions embedded in the CBAM materials you bought and consumed, divided by the tonnes of product you made.
The result is tonnes of CO₂e per tonne of goods for one calendar year. Scrap and returned product are excluded from output; offcuts and losses stay on the input side.
Source: Regulation (EU) 2023/956, Annex IV
Do electricity emissions count for steel and aluminium under CBAM?
No — in the definitive period only direct emissions count for iron, steel and aluminium; electricity is reported in the template but does not enter the product's value, with sintered ore as the single exception.
Electric arc furnace producers still count electrodes, natural gas and the carbon in scrap and alloys.
Source: Regulation (EU) 2023/956, Annex II; Commission Guidance No. 5d/5e, pp. 8–9
Does steel or aluminium I buy in count towards my CBAM figure?
Yes — purchased CBAM material such as rod, coil, billet or unwrought aluminium carries its producer's emissions into your product, and for fabricators it is usually most of the total.
Enter the tonnes consumed, not the tonnes that end up in the product: if 100 tonnes of rod go in and 80 tonnes of screws come out, the figure is 100.
Source: Commission Guidance No. 3, pp. 34, 68
How much does CBAM cost my EU customer?
Roughly: tonnes imported × emissions per tonne × the EU carbon price × the phase-in factor, which is 2.5% in 2026 and rises to 100% by 2034.
Using the default value with its mark-up instead of your real figure raises the emissions per tonne, and therefore the cost, for every tonne.
Source: Regulation (EU) 2023/956, Article 31
Last updated 2026-10-05.
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