EU CBAM scope checker
Catch the CBAM exposure before the certificate stack lands on the declaration.
Preview · example result
In CBAM scope under iron and steel category. Importer must hold CBAM declarant authorisation and submit quarterly emissions reports.
Hot-rolled flat products of iron or non-alloy steel
CBAM IN SCOPEPro members only
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The preview above runs against the 536-CN-code Annex I seed bundled with the live tool. Pro at USD 59 per month unlocks the interactive scope checker (paste any CN code, get in-scope determination + category + reporting obligation hedged to EUR-Lex) alongside the AU and US AD/CVD lookups, the EU REACH SVHC and Annex XIV lookup, the US HTS chapters 28 to 39 lookup, the AU landed-cost calculator, the DFAT sanctions screener, and the AICIS checker.
Pro is for the procurement and compliance team that imports into the EU every month and needs the binding CN scope one tab away on every shipment qualification call. Cancel anytime from /account.
Worked example: hot-rolled coil from a non-EU mill
A Hamburg fabricator buys 800 tonnes of hot-rolled steel coil per quarter from a non-EU mill. The buyer ships against CN 7208.39.00 (flat-rolled, hot-rolled, not pickled, thickness less than 3 mm). Through the transitional period the buyer was filing the quarterly CBAM report under Reg (EU) 2023/1773, declaring estimated embedded emissions of approximately 2.0 tonnes CO2e per tonne of finished steel based on the mill default. Nothing financial was happening at the border; nothing financial felt like nothing to budget for.
The first definitive-period declaration covers calendar year 2026 and is lodged in 2027. At an EU ETS reference of around 80 EUR per tonne CO2e and 2.0 tonnes embedded per tonne of finished steel, the CBAM certificate cost lands at roughly 160 EUR per tonne of imported steel. On 800 tonnes per quarter, 3,200 tonnes per year, that is a CBAM certificate surrender of around 512,000 EUR for the year. The lookup catches this earlier: search 7208 in the box above and the result panel returns the in-scope row, the EUR-Lex link to the binding regulation, the phase dates, and the sector grouping. The buyer reads the row, opens Reg 2023/956 to the Annex I iron-and-steel block, and is now ready to brief the finance team that 2026 CBAM exposure is a real line on the P&L.
The fix is two-sided. On the supplier side, lock in verified rather than default embedded emissions: a verified report from the non-EU mill with installation-specific data typically lands below the default for modern mills and the certificate-surrender cost falls in proportion. On the demand side, qualify EU-origin or EFTA-origin alternatives where economics permit; goods originating in Norway, Iceland, Liechtenstein, or Switzerland do not generate a CBAM obligation. The lookup is the first scan; the verified-emissions filing and the qualified-supplier alternative are the next two operator moves.
Frequently asked
What is the EU CBAM and which goods does it cover?
The Carbon Border Adjustment Mechanism is the EU regime under Regulation (EU) 2023/956 that prices the embedded greenhouse-gas emissions of certain imported goods at the EU border. The scope at first stage covers six sectors listed in Annex I: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The CN code on the customs entry is the binary in-scope vs out-of-scope test. Goods outside the Annex I CN list do not generate a CBAM obligation today, even if they have material embedded emissions, until the scope is extended by a future amending regulation.
Why does the tool describe CBAM as certificates rather than a cash deposit?
CBAM is administered through CBAM certificates rather than a customs cash deposit. During the transitional period from 1 October 2023 to 31 December 2025, importers report embedded emissions quarterly with no financial obligation. From 1 January 2026, the definitive period begins: an authorised CBAM declarant submits an annual declaration of embedded emissions and surrenders one CBAM certificate per tonne of CO2-equivalent declared. Certificate price is the weekly average closing price of EU ETS allowances. The end-of-year reconciliation captures the financial obligation; there is no daily cash deposit at the border the way an anti-dumping order works.
What if my product is not on the Annex I CN list?
Out-of-scope today. The Commission has signalled a CBAM Phase 2 review that may extend coverage to organic chemicals, polymers, refineries, and downstream steel and aluminium articles, but until that amending regulation is published in the Official Journal, the operative scope is the Annex I list shipped here. Operators should monitor EUR-Lex and DG TAXUD for the review outcome; phase 2 timelines have shifted in published Commission communications.
How does CBAM interact with EU ETS?
CBAM is calibrated against the EU Emissions Trading System price. Importers surrender CBAM certificates priced at the weekly average of EU ETS allowance auction prices. As the EU ETS free-allocation share is phased out for CBAM sectors from 2026, the CBAM obligation scales up to match. Operators in CBAM sectors should track both the EU ETS price index and the free-allocation phase-out schedule, because the effective CBAM cost is the certificate price net of any free allocation still held by the equivalent EU producer.
Are EFTA goods exempt from CBAM?
Goods originating in Norway, Iceland, Liechtenstein, and Switzerland are not subject to CBAM (per Reg (EU) 2023/956 Article 2 and the EEA agreement framework). Goods originating in any country participating in the EU ETS or in a carbon-pricing scheme deemed equivalent by the Commission may also be exempt; the list is published by Commission Implementing Regulation and updated. Importers must hold proof of origin to claim the exemption at customs.
Does CBAM cover indirect emissions (Scope 2)?
For cement, fertilisers, and hydrogen, the scope includes indirect emissions from electricity consumed in production from the start of the definitive period. For iron and steel and aluminium, indirect emissions remain outside the scope at this stage. The exact methodology for calculating indirect emissions sits in Reg (EU) 2023/1773 and subsequent Implementing Regulations. Verify the current methodology against EUR-Lex before reporting.
Related tools
Once a CN code is confirmed in CBAM scope, run the FOB to landed-cost stack through the AU landed cost calculator (AU import side) or the US HTS chapters 28 to 39 + Section 301 lookup if the same supplier ships to the US under chemicals coverage. For substance-level REACH exposure on the same import (SVHC documentation duty and Annex XIV market-access prohibition), the EU REACH SVHC and Annex XIV lookup sits one tab away.