Updated September 2026 · EU Steel Compliance

CBAM for Steel Imports 2026:
What EU Buyers and Steel Suppliers Need to Know

The EU Carbon Border Adjustment Mechanism entered its
definitive regime on 1 January 2026.
For covered iron and steel imports, CBAM connects the carbon emissions
embedded in imported goods with the carbon price faced by producers
under the EU Emissions Trading System.

EU importers above the applicable
50-tonne annual threshold must address CBAM
authorisation, emissions reporting and certificate obligations.
Non-EU steel producers may need to provide installation,
production-route and emissions information so their European customers
can meet those obligations.

Definitive regime: 1 January 2026
Iron & Steel Sector
Updated EU Guidance: August 2026

1 Jan 2026
Definitive CBAM regime
50 t
Single annual mass threshold
30 Sep 2027
First declaration for 2026 imports
Feb 2027
Certificate purchasing begins

Important September 2026 Update

On 14 August 2026, the European Commission published new
definitive-period guidance, including

Guidance No. 5d — Sector-Specific Guidance on Iron and Steel
.

The Commission also published corrected definitive-period default
values in August 2026 and updated verification guidance.
Companies preparing 2026 data should therefore use current
definitive-period methodology rather than older transitional guidance.

CBAM for Steel Imports 2026: Quick Overview

CBAM is an EU carbon-pricing mechanism covering selected imported goods.
For iron and steel, whether a product falls within CBAM depends on its
Combined Nomenclature (CN) code, not simply on a
commercial description such as steel plate, stainless steel sheet
or steel coil.

Item 2026 Position
Main regulation Regulation (EU) 2023/956, as amended
Definitive regime From 1 January 2026
Steel sector Selected iron and steel goods listed within CBAM scope
Mass threshold 50 tonnes per importer per calendar year for relevant sectors
Authorised declarant Required for importers or applicable indirect customs
representatives above the relevant threshold
2026 certificate pricing Quarterly
Certificate purchasing From February 2027 for 2026 imports
First annual CBAM declaration By 30 September 2027 for 2026 imports

Key distinction:
the non-EU steel supplier normally provides production and emissions
information. The EU importer or authorised CBAM declarant is responsible
for its own CBAM declaration and certificate obligations.

Does CBAM Apply to Your Steel Shipment?

A steel buyer should not decide CBAM scope from a product description
alone. A practical assessment starts with the CN code and then considers
the importer, annual quantity and applicable compliance requirements.

1

Check the CN Code

Identify the customs classification and confirm whether that CN code
appears within Annex I of the CBAM Regulation.

2

Check Annual Import Volume

Determine whether the importer exceeds the applicable
50-tonne single mass-based threshold
during the calendar year.

3

Identify the Declarant

Determine whether the EU importer or its applicable indirect customs
representative is responsible for the CBAM declaration.

4

Prepare Emissions Data

Determine whether default values or actual verified emissions data
will be used and collect the required production information.

What Changed When CBAM Entered the Definitive Regime?

The transitional period from October 2023 through December 2025 focused
mainly on reporting. The definitive regime introduces a different
compliance environment.

Topic Transitional Period Definitive Regime
Period 2023–2025 From 1 January 2026
Main focus Emissions reporting and data collection Reporting plus financial CBAM obligations
Certificates No certificate surrender Certificates must ultimately be surrendered for covered
embedded emissions, subject to applicable adjustments
Actual emissions Transitional reporting methodology Definitive-period methodology and verification requirements

Which Iron and Steel Products Are Covered by CBAM?

CBAM applies to selected iron and steel goods listed in Annex I of
Regulation (EU) 2023/956. Scope is based on
CN classification.

Depending on the exact CN code, covered goods can include:

  • Iron ores and certain sintered products
  • Pig iron
  • Direct reduced iron
  • Ferro-alloys within covered classifications
  • Crude steel
  • Selected flat-rolled iron or steel products
  • Selected long steel products
  • Selected pipes, tubes and hollow sections
  • Other covered iron and steel articles listed in Annex I

Stainless Steel Should Be Checked by CN Code

A commercial description such as “304 stainless steel sheet” or
“316L stainless steel coil” is not by itself enough to establish
CBAM treatment. Product form, dimensions, composition and customs
classification should be reviewed against the current CBAM scope.

How Does the 50-Tonne CBAM Threshold Work?

The current CBAM Regulation sets a
single mass-based threshold of 50 tonnes net mass.
The importer’s annual imports across the applicable iron and steel,
aluminium, cement and fertiliser sectors are considered for this
threshold.

At or Below the Threshold

An importer that remains within the applicable single mass-based
exemption may fall outside the corresponding CBAM obligations
covered by that exemption.

Once the Threshold Is Exceeded

If the importer exceeds the threshold during the calendar year,
CBAM obligations apply to relevant goods imported during that
calendar year, not simply the quantity above 50 tonnes.

EU Importer vs Non-EU Steel Supplier: Who Does What?

EU Importer / Authorised CBAM Declarant

  • Checks whether imported goods fall within CBAM scope
  • Manages applicable CBAM authorisation requirements
  • Uses the CBAM Registry
  • Collects required embedded-emissions information
  • Submits the annual CBAM declaration
  • Purchases and surrenders applicable CBAM certificates

Non-EU Steel Producer / Supplier

  • Identifies the producing installation
  • Provides relevant production-route information
  • Maintains appropriate emissions monitoring information
  • Provides actual emissions data where applicable
  • Provides precursor information where required
  • Supports verification where actual data is used

What CBAM Data May an EU Steel Buyer Need From Its Supplier?

Product & Installation Data

  • Product description
  • Relevant CN code information
  • Quantity of product
  • Producing installation
  • Country of production
  • Production route
  • Applicable reporting period

Emissions & Production Data

  • Specific embedded emissions
  • Direct emissions information
  • Relevant precursor embedded emissions
  • Production quantities
  • Material-flow information
  • Supporting records for verification

How Are Embedded Emissions Treated for Iron and Steel?

CBAM is based on greenhouse gas emissions embedded in covered goods.
For iron and steel under the definitive-period framework,
direct emissions are central to the calculation.

Relevant emissions associated with precursor materials may also need
to be carried through the production chain when calculating embedded
emissions for more complex steel products.

Product quantity
×
specific embedded emissions
→
embedded emissions associated with imported goods

Actual Emissions vs CBAM Default Values

Actual Emissions

  • Can reflect the specific installation more accurately
  • Requires appropriate monitoring methodology
  • Requires supporting production records
  • Requires verification where applicable

Default Values

  • Defined by the European Commission
  • Not supplier-selected estimates
  • Correct CN classification remains essential
  • Current definitive-period values should be used

Does Actual Steel Emissions Data Need Verification?

1. Steel Producer

Establishes monitoring processes and prepares production and
embedded-emissions information.

2. Accredited Verifier

Performs verification under the applicable CBAM verification
framework.

3. CBAM Declarant

Uses the required emissions information for its CBAM declaration
and compliance obligations.

How Much Does CBAM Cost for Steel Imports?

There is no single fixed CBAM charge per tonne of steel.
Certificate prices are linked to EU ETS allowance prices and the
required number of certificates depends on embedded emissions and
applicable regulatory adjustments.

2026 Quarter CBAM Certificate Price
Q1 2026 €75.36
Q2 2026 €75.28
Q3 2026 To be published
Q4 2026 To be published

Embedded emissions
×
applicable certificate requirement
×
certificate price

CBAM vs EU Steel Import Quotas: What Is the Difference?

CBAM and the EU steel tariff-rate quota system are
separate regulatory systems.
A steel shipment entering the European Union may need to consider both.

Topic CBAM EU Steel Quota System
Main purpose Carbon pricing for embedded emissions Management of covered steel import volumes
Main classification basis CBAM-covered CN codes Steel quota CN codes and product categories
Main commercial exposure CBAM certificate obligations 50% out-of-quota duty
Important supplier data Production and embedded-emissions information Classification, origin and melt-and-pour information
Same regulation? No No

Also Check EU Steel Quota Exposure

CBAM compliance does not replace EU steel tariff-quota requirements.
Covered steel may also be affected by product-specific quotas,
a 50% out-of-quota duty and
melt-and-pour documentation requirements.


Read the Complete EU Steel Import Quotas 2026 Guide →

CBAM Checklist for Chinese Steel Suppliers

  • Confirm the steel product, grade and product form.
  • Provide information needed to support correct CN classification.
  • Identify the producing installation.
  • Identify the production route.
  • Establish appropriate emissions monitoring records.
  • Identify relevant precursors used in production where required.
  • Maintain traceable production and material records.
  • Prepare actual embedded-emissions data where appropriate.
  • Prepare for verification where required.
  • Keep commercial, production and CBAM-related data internally
    consistent.

How LYH Steel Supports European Buyers

LYH Steel supplies stainless steel, carbon steel and related metal
products for international projects. For EU-bound enquiries, we can
support the procurement process with product specifications,
available mill information, traceability documentation and
coordination of customer data requirements.

Product & Specification Support

  • Steel grade matching
  • Sheet, plate and coil sourcing
  • Standard and specification review
  • Thickness and dimensional requirements
  • Processing options

Traceability & Data Coordination

  • Mill information where available
  • Heat-number traceability
  • Mill Test Certificates where applicable
  • Production information coordination
  • Quality inspection documentation

Related Resources for EU Steel Buyers



EU Steel Import Quotas 2026
Understand the 26 product categories, 50% out-of-quota duty,
quota administration and melt-and-pour requirements.


Steel Products
Browse stainless steel, carbon steel and related product forms.


Stainless Steel Grades
Review common stainless steel grades and material options.


Steel Grade Equivalent Chart
Compare AISI, UNS, EN, DIN, JIS, GOST and GB grade systems.


Quality Inspection
Review LYH Steel inspection and quality-control support.


Stainless Steel Supplier Guide
Prepare specifications and compare steel suppliers more effectively.

Official EU CBAM Sources

CBAM is a regulatory compliance subject. Importers and suppliers should
use current European Commission and EUR-Lex sources when making
shipment-specific decisions.

Primary Sources Used for This Guide

Frequently Asked Questions About CBAM for Steel Imports

What is CBAM for steel imports?

CBAM is the EU Carbon Border Adjustment Mechanism. It applies a
carbon-pricing framework to embedded emissions in selected
imported goods, including covered iron and steel products.

Does CBAM apply to stainless steel?

Some stainless steel products can fall within CBAM scope.
Coverage should be determined using the applicable CN code
rather than the commercial grade name alone.

What is the 50-tonne CBAM threshold?

The current framework uses a single mass-based threshold of
50 tonnes net mass per importer per calendar year for the
applicable sectors.

Who is responsible for CBAM on steel imported from China?

The EU importer or relevant authorised CBAM declarant is
responsible for CBAM declaration and certificate obligations.
The Chinese steel supplier may need to provide production and
embedded-emissions information.

When is the first CBAM declaration due?

The first annual CBAM declaration covering imports made during
2026 is due by 30 September 2027.

Are CBAM and EU steel quotas the same regulation?

No. CBAM concerns embedded carbon emissions and carbon pricing.
EU steel quotas manage covered import volumes and can impose a
50% out-of-quota duty.


Read our EU Steel Import Quotas 2026 Guide →

Preparing Steel Supply Chains for EU CBAM

The definitive CBAM regime makes emissions information part of the
commercial and regulatory workflow for covered EU steel imports.
Importers need to understand product scope, the 50-tonne threshold,
declarant obligations, embedded emissions, verification and certificate
requirements.

Non-EU steel suppliers should focus on maintaining reliable production
data, identifying the producing installation and production route,
supporting emissions calculations and providing documentation that
their EU customers can use within the CBAM compliance process.

Planning a Steel Purchase for the EU?

Send LYH Steel your required grade, standard, dimensions, quantity,
product form and destination. We can help you review suitable products,
processing options and available mill and traceability documentation.


Request a Steel Quotation


Browse Steel Products


EU Steel Quotas Guide

Regulatory notice:
This guide provides general procurement and regulatory information.
It does not constitute legal, customs, tax, carbon-accounting or
verification advice. CBAM scope, CN classification, methodologies,
default values and certificate prices can change. Importers should
verify current EU legislation and confirm shipment-specific obligations
with qualified advisers and relevant authorities.

Last updated:
September 2026.

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