CBAM by sector
CBAM and Iron & Steel
Iron and steel is the largest of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). If you import iron or steel — including many downstream items such as tubes, structures, tanks and fasteners — you may have CBAM obligations once your annual imports cross the 50-tonne threshold. This page explains what is covered and what to do.
Iron & steel
Direct emissions · 50 t threshold
TL;DR
- Iron & steel is in scope under Regulation (EU) 2023/956, defined by the CN codes listed in Annex I.
- Coverage reaches downstream products too: tubes and pipes, structures, tanks and fasteners (screws, bolts, nuts, washers).
- Embedded emissions for steel are largely direct (the indirect, electricity-based share is treated more narrowly than for cement or fertilisers).
- Steel counts toward the cumulative 50-tonne annual de-minimis threshold; importers under 50 tonnes/year of covered goods are exempt.
In scope
What CBAM covers for iron & steel
- Pig iron, ferro-alloys and crude steel products (the upstream of the sector).
- Tubes and pipes, and tube or pipe fittings, of iron or steel.
- Structures and parts of structures (for example bridges, towers, columns) of iron or steel.
- Reservoirs, tanks and similar containers of iron or steel.
- Fasteners: screws, bolts, nuts, coach screws, washers and similar articles of iron or steel.
Annex I lists each product by its CN code, so you confirm scope by matching your customs code — not just the word "steel". A steel sheet is covered, but a car body made of steel is not (its CN code sits outside Annex I).
These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.
Emissions
How embedded emissions are counted
Emissions are counted as direct emissions. For iron & steel, CBAM focuses on direct emissions from the production process. The indirect, electricity-based share is treated more narrowly than for cement and fertilisers, reflecting how EU producers’ indirect costs are addressed. Regulation (EU) 2023/956
Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.
The 50-tonne threshold
Does the de-minimis exemption apply?
Iron & steel counts toward the 50-tonne threshold
The hard part
The hard part for iron & steel
- Downstream creep: many finished steel articles (fasteners, structures, tanks) are in scope, so importers who think of themselves as buying "products" rather than "steel" can be caught.
- Confirming CN codes: scope turns on the exact eight-digit CN code, and a single product line can span several codes.
- Getting installation-level emissions data from mills, which may be reluctant or unable to share verified figures.
- Tracking cumulative tonnage across all four mass-counted sectors to know when you cross 50 tonnes.
What to do
What to do for iron & steel
- Confirm scope by matching every iron and steel product line against the CN codes in Annex I.
- Add up your annual net mass across steel, aluminium, cement and fertilisers to see whether you cross the 50-tonne threshold.
- Ask your suppliers for actual, verified embedded-emissions data (usually cheaper than default values).
- If you import above the threshold, become an authorised CBAM declarant (or use an indirect customs representative who is) via the CBAM Registry.
- Gather embedded-emissions data from your suppliers, or fall back to the published default values, then file your annual CBAM declaration and surrender certificates by 30 September of the following year.
For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.
FAQ
Iron & steel and CBAM: common questions
- Are steel fasteners (screws, bolts, nuts) covered by CBAM?
- Yes. Annex I of Regulation (EU) 2023/956 lists certain iron and steel fasteners — screws, bolts, nuts, washers and similar articles — among the covered goods. Confirm each product by its CN code, since coverage turns on the code rather than the product name.
- Is scrap steel covered by CBAM?
- Iron and steel scrap generally sits outside the in-scope CN codes in Annex I, but you should confirm your specific code. Coverage is driven by the CN code of the imported good, so always match against the current Annex I rather than assuming.
- Are indirect emissions counted for steel?
- For iron & steel, CBAM focuses on direct emissions from production. The indirect (electricity) share is treated more narrowly than for cement and fertilisers. Check the latest implementing rules, as the exact treatment of indirect emissions has been refined over time.
- When do steel importers have to comply with CBAM?
- The definitive period began on 1 January 2026. If your annual imports cross the 50-tonne threshold you must be (or use) an authorised CBAM declarant. The first annual declaration and certificate surrender for 2026 imports is due 30 September 2027.
Get ready for CBAM
Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
- [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
- [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
- [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026
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