CBAM Reporting for Steel Importers: CN Codes & Compliance

Steel and iron products account for the largest volume of CBAM-covered imports. This guide covers everything steel importers need for compliant quarterly reporting.

CN Codes for Steel and Iron Products

Steel products fall under CN Chapter 72 (Iron and Steel) and selected codes in Chapter 73 (Articles of Iron or Steel):

Product Type	CN Code Range	Examples
Primary products	7201–7205	Pig iron, ferro-alloys
Semi-finished	7206–7207	Ingots, blocks, billets
Flat-rolled	7208–7212	Sheets, plates, coils
Long products	7213–7216	Bars, rods, angles
Wire	7217	Steel wire
Tubes and pipes	7301–7306	Seamless, welded

Each CN code has specific default emission factors based on production method and country of origin.

Emission Factors by Production Method

Steel production methods have significantly different emission profiles:

Blast Furnace (BF-BOF)

• High emissions: ~1.5–2.5 tCO₂e/tonne
• Dominant method in most countries
• Higher default factors apply

Electric Arc Furnace (EAF)

• Lower emissions: ~0.3–0.8 tCO₂e/tonne
• Growing market share
• Lower default factors

Direct Reduced Iron (DRI)

• Medium emissions: ~0.8–1.5 tCO₂e/tonne
• Used with natural gas or hydrogen
• Country-dependent factors

Country-Specific Factors

Default emission factors vary significantly by country of origin. For example, steel rebar (CN 7214):

Country	Direct Factor (tCO₂e/t)	Indirect Factor (tCO₂e/t)
Turkey	0.535	0.137
China	1.824	0.412
India	1.615	0.389
South Korea	0.723	0.184
Japan	0.698	0.176

Always verify that you are using the correct factor for both the product type AND the country of origin.

Data Collection for Steel Products

Required Data Points

• Steel product type (specific CN code)
• Quantity imported (tonnes)
• Production method (BF, EAF, or DRI)
• Country of origin
• Supplier emission data (if using actual factors)

Documentation to Maintain

• Mill test certificates
• Supplier emission declarations
• Bills of lading
• Customs import declarations

CbamTrack includes pre-configured product templates for steel importers to streamline data entry and ensure nothing is missed.

Common Steel-Specific Errors

Mixing CN codes — Flat and long products have different codes and factors. Verify each product type separately.

Ignoring production method — The same product from the same country can have different factors depending on whether it was made in a blast furnace or electric arc furnace.

Wrong country factors — Using generic EU averages instead of country-specific default factors will produce incorrect emission calculations.

FAQ

Do I need to report separately for each steel grade? Report at the CN code level. Different grades within the same CN code use the same emission factor.

How do I handle scrap-based steel? Scrap-based (EAF) steel has lower default factors. Ensure the production method is correctly documented.

What about coated or treated steel products? Coated steel products may fall under different CN codes. Verify the correct classification before reporting.

Streamline Your Steel CBAM Reporting

Steel importers face the most complex CBAM reporting requirements due to multiple production methods and country-specific factors. CbamTrack handles CN code mapping, factor selection, and emission calculation automatically.