CBAM for steel importers
Iron and steel is the highest-volume group under the CBAM. Import pig iron, semi-finished products, flat or long products, tubes or certain steel articles, and you are almost certainly in scope. You cross the quantity threshold fast.
- Iron and steel covers a wide range of CN codes, from pig iron to intermediate products.
- High import volumes clear the 50-tonne de minimis threshold with ease.
- Real emission data from the mill almost always beats conservative default values.
What exactly is in scope
The CBAM attaches to the goods code, not to the industry. In steel that pulls in pig iron and spiegeleisen, semi-finished iron and steel, hot- and cold-rolled flat products, long products, tubes and selected steel articles. Whether a given consignment is caught is decided by the eight-digit CN number on your customs declaration. A clean mapping of your articles to CN codes is therefore the first step, not a formality at the end.
Why steel is a question of volume
Steel is rarely imported in token amounts. Anyone buying regularly accumulates well over 50 tonnes of net mass across the year. The de minimis threshold that relieves smaller importers does not help most steel importers. Declarant status, data obligations and cost effect are all on the table.
Default values are the expensive option
Where no actual emission values from the producer are available, default values apply. They are deliberately conservative and rise over the years. With steel and its large volumes, every excess tonne of CO2 equivalent lands straight in the budget. Real data from the mill is the single biggest cost lever here.
The planned extension from 2028
In December 2025 the European Commission proposed extending the scope from 2028 to numerous downstream steel and aluminium products. That is a proposal, not yet law. Importers of structural steel, components and processed goods should still watch it. Know your supply chain today and tomorrow holds no surprise.
Written and maintained by the EnergyFlow Regulatory Desk, the CBAM-focused division of EnergyFlow GmbH. As of June 2026. Legal basis: Regulation (EU) 2023/956, amended by the Omnibus Regulation (EU) 2025/2083 (Official Journal of the EU, 17 October 2025). Primary sources: EUR-Lex and the official CBAM page of the European Commission.
Information on the CBAM is given to the best of our knowledge, as of June 2026, without guarantee. Dynamic values such as certificate prices, default values and deadlines can change. The applicable legal acts and the competent authorities are decisive. This article is not legal, tax or customs advice.
What does this mean for your imports?
General explanations are a start. The CBAM Decision File examines your specific case in seven working days.