CBAM Reporting for Steel Importers
Complete guide to CBAM compliance for iron and steel imports. CN codes, emission factors, production routes, and free allocation — all in one place.
Steel Importers Face Unique Challenges
Complex CN Codes
Steel spans CN Chapters 72-73 with dozens of codes. Each has different emission factors and benchmarks.
Production Route Matters
BF-BOF, DRI-EAF, or Scrap-EAF — each route has vastly different emission profiles and free allocation benchmarks.
Indirect Exemption Confusion
Steel is the only sector with indirect emission exemption for free allocation. Getting this wrong overstates your liability.
Quarterly Deadline Pressure
Missing the CBAM reporting deadline triggers penalties. Manual calculations take hours.
CBAM-Covered Steel CN Codes
| CN Code | Product | Benchmark |
|---|---|---|
| 7208 | Flat-rolled products (hot-rolled) | 1.370 tCO₂e/t |
| 7209 | Flat-rolled products (cold-rolled) | 1.370 tCO₂e/t |
| 7210 | Flat-rolled products (coated) | 1.370 tCO₂e/t |
| 7213 | Bars and rods (hot-rolled) | 1.370 tCO₂e/t |
| 7214 | Other bars and rods | 1.370 tCO₂e/t |
| 7219 | Stainless steel flat-rolled | 1.370 tCO₂e/t |
| 7304 | Seamless tubes and pipes | 1.370 tCO₂e/t |
| 7306 | Other tubes and pipes | 1.370 tCO₂e/t |
Benchmarks apply per production route (BF-BOF, DRI-EAF, Scrap-EAF). See IR 2025/2620 for full details.
How CbamTrack Helps Steel Importers
Production Route Selection
Select BF-BOF (1.370), DRI-EAF (0.481), or Scrap-EAF (0.072) — correct benchmark applied automatically.
Automatic Indirect Exemption
Steel products (CN 72xx) get indirect emission exemption for free allocation. CbamTrack handles this automatically.
One-Click Reports
Generate quarterly CBAM declarations with all required fields, compliant with IR 2025/2621.
Audit-Ready Output
PDF and XML export formats accepted by EU competent authorities. 5-year retention compliant.
Frequently Asked Questions
Which steel CN codes are covered by CBAM?▼
CBAM covers iron and steel products under CN Chapters 72 and 73. This includes flat-rolled products (7208-7212), bars and rods (7213-7216), stainless steel (7218-7223), and tubes/pipes (7304-7306). Over 30 CN codes are covered.
Is steel indirect emissions exempt from CBAM?▼
Yes. Steel products (CN 72xx) benefit from indirect emission exemption for free allocation under IR 2025/2620. This means indirect emissions from electricity are excluded when calculating your free allocation deduction. However, you still need to report them.
What is the BF-BOF benchmark for steel?▼
The BF-BOF (Blast Furnace — Basic Oxygen Furnace) benchmark is 1.370 tCO₂e/tonne under IR 2025/2620. This is the most common steel production route and has the highest benchmark value.
How does production route affect my CBAM cost?▼
Production route significantly impacts your CBAM liability. EAF (Electric Arc Furnace) production has much lower emissions (0.072-0.481 tCO₂e/tonne) compared to BF-BOF (1.370 tCO₂e/tonne). Using actual data from EAF producers can reduce your costs by 60-95%.
Do I need to report steel indirect emissions?▼
Yes, you must report indirect emissions for all steel products. However, for free allocation calculation purposes, indirect emissions are exempt for CN 72xx products only. CbamTrack handles this distinction automatically.
What is the free allocation phase-out for steel?▼
Free allocation starts at 97.5% in 2026 (2.5% phase-out) and decreases annually until reaching 0% in 2034. This means your CBAM certificate cost will increase over time as free allocation decreases.
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