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CBAM for Iron & Steel Imports

The largest CBAM sector by import volume. Understand your obligations across pig iron, flat-rolled coil, tubes, pipes, and fabricated steel articles — for both BF-BOF and EAF production routes.

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1.89tCO₂e / tonne (HRC default)
CN 72–73HS chapters in scope
~7–9%of global CO₂ emissions

Which iron and steel products are in CBAM scope?

Iron and steel is the broadest CBAM sector. Key product categories include:

CN CodeProductNotes
7201Pig iron & spiegeleisenDirect emissions ~1.3–1.6 tCO₂/t BF
7202Ferro-alloysHighly variable by alloy type
7207–7215Semi-finished & long productsBillets, bars, rods, wire rod
7208–7212Flat-rolled products (hot/cold rolled)~1.5–2.2 tCO₂/t BF-BOF / 0.4–0.8 EAF
7219–7220Stainless steel flat productsIncludes Cr/Ni alloying emissions
7301–7326Tubes, pipes, fittings, fabricated articlesDownstream products — check individual CN codes

Key CBAM rules for steel

Both direct and indirect emissions

Unlike cement, steel CBAM includes both direct process emissions (blast furnace, EAF arc) and indirect emissions from electricity consumption. This is especially significant for EAF producers where electricity is the dominant energy input.

Production-route matters

BF-BOF (integrated mills) typically emit 1.8–2.2 tCO₂/t. EAF (scrap-based) can be as low as 0.4–0.6 tCO₂/t using a clean grid. Providing route-specific verified data can significantly reduce your CBAM liability.

Downstream product complexity

Many downstream steel articles (tubes, pipes, structural sections) are in CBAM scope. The embedded emissions of the upstream steel are attributed to these products, so importers must trace back to the hot-rolled coil or billet emission factor.

Precursor accounting

If you import hot-rolled coil that was produced from in-scope pig iron or scrap, the emissions of the precursor stage must be included in the total embedded emission declaration.

Frequently asked questions

Which steel products are covered by CBAM?

CBAM covers a wide range under CN chapters 72–73: pig iron, ferro-alloys, flat-rolled products (HRC, CRC, coated), long products (bars, rods, wire), stainless steel, tubes and pipes, and many fabricated steel articles. Consult Annex I of Regulation (EU) 2023/956 for the definitive CN code list.

Do indirect electricity emissions apply to steel?

Yes. For steel, both direct emissions (from furnaces and processes) and indirect emissions (from electricity consumed during production) must be included in the embedded emissions declaration. The indirect portion is calculated as electricity consumption × the grid emission factor of the producing country.

What is the default emission factor for steel?

There is no single default — it varies by product and route. Hot-rolled coil (BF-BOF route) defaults to approximately 1.89 tCO₂e/t. EAF-produced rebar from the EU grid may be as low as 0.35 tCO₂e/t. Our calculator uses the BF-BOF reference as the conservative default.

Are stainless steel and special alloys in CBAM scope?

Stainless steel flat products (CN 7219–7220) are in scope. For special alloys, check the specific CN code against Annex I. Some ferro-alloys (CN 7202) are also covered. High-alloy tool steels may or may not be in scope depending on their specific classification.

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