CBAM Sector Brief · Steel
CBAM compliance for steel importers
If your business imports steel into the EU above 50 tonnes per year, you need Authorised CBAM Declarant status before clearing customs. Carbon Border generates the full NCA application, collects verified mill emissions, and procures CBAM certificates each quarter.
Who needs CBAM authorisation for steel?
Any EU-established importer whose annual volume of CN heading 72 (iron & non-alloy steel) and CN heading 73 (articles of iron or steel) exceeds 50 tonnes across all EORIs. This includes hot-rolled coil, rebar, structural sections, tubes, fasteners, screws, wire, and downstream fabricated articles. Indirect importers using customs representatives are also captured.
How embedded emissions are calculated
Embedded emissions are calculated per tonne of finished product using the EU CBAM methodology (direct + relevant indirect emissions). For integrated routes (BF-BOF) the system boundary covers sintering, coke-making, hot-metal and steel-making. For EAF routes it covers scrap melting and finishing. Where the mill cannot supply verifier-signed data, the EU default value applies with a 10% markup in 2026.
In 2026, the EU default value carries a +10% markup when the importer cannot present verifier-signed supplier emissions. Verified data nearly always lowers your CBAM certificate liability — Carbon Border collects it for you via secure supplier portals.
Common HS / CN codes in this sector
Top origin countries currently subject to CBAM filings for this category include Türkiye, India, South Korea, Ukraine, China.
UK CBAM (from 2027)
The UK CBAM goes live on 1 January 2027 and covers iron and steel from day one. The verification, supplier evidence and quarterly reporting workflow Carbon Border builds for EU CBAM is reused 1-to-1 for UK declarations to HMRC, so importers operating across both customs territories only set up once.
What Carbon Border does for steel importers
- Generates the full NCA Application Pack (Operational Capacity, Financial Exposure, HS-Code Alignment)
- Logs every shipment against the live ETS price and your verified emissions data
- Sends secure supplier portals so mills, smelters and producers upload signed emissions data
- Procures the right number of CBAM certificates each quarter via Stripe
- Maintains the 5-year audit trail required by Article 30 of Reg. (EU) 2023/956
- Mirrors the same workflow for the UK CBAM going live in 2027
Frequently asked questions
Does CBAM apply to downstream steel articles like fasteners and bolts?
Yes. Annex I of Reg. (EU) 2023/956 includes a wide range of downstream iron and steel articles under CN heading 73, such as screws, bolts, nuts, washers (7318), tubes (7304-7306), and structural elements (7308).
Does the 50-tonne de minimis apply per shipment or per year?
Per importer per calendar year, aggregated across all CBAM-scope CN codes you import (steel + aluminium + cement + fertilisers combined). Once cumulative imports exceed 50 t, every subsequent shipment is in scope.
What if my Turkish or Indian mill won't share emissions data?
You can default to the EU benchmark embedded emissions value, but that value carries a 10% markup in 2026 and uses a worst-case route assumption. Carbon Border's supplier portal makes the data request a 5-minute task for the mill — they upload the verifier statement and we map it to your shipments automatically.
How are CBAM certificate prices set?
Each CBAM certificate represents 1 tCO₂ and is priced at the average weekly EU ETS auction clearing price. Carbon Border buys the right quantity each quarter from the Common Central Platform, against your verified shipment ledger.
Will UK CBAM use the same data?
Yes. UK CBAM (effective 1 January 2027) follows a near-identical embedded-emissions methodology for steel. The same supplier emissions data, mill certifications and shipment ledger Carbon Border maintains for EU CBAM is exported to HMRC's UK CBAM declarations.
Become an Authorised CBAM Declarant for steel
Generate your NCA Application Pack in under 30 minutes. €1,499 one-time, then a metered subscription.
Create your account