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CBAM for steel and iron imports: what the certificate line looks like

By Jai Nischal Verma · Prices checked 31 Oct 2026 · EU law guide

CBAM Cost Guide for Steel Imports: What the certificate line looks like

Law last checked: 31 October 2026. Figures below are copied from the EU texts linked in Sources. This is general information, not legal, tax or customs advice. Rules and prices change; confirm them before you import.

Steel is the CBAM good most importers meet first, because so much of it moves. The rule is narrower than “anything made of iron.” Annex I names the CN codes, and it leaves a few famous headings outside.

What counts as iron and steel

Chapter 72 is in, except a list of ferro-alloys (ferro-silicon, ferro-silico-manganese and the others named in the annex) and heading 7204, which is ferrous waste and scrap[3]. Agglomerated iron ores under 2601 12 00 are in. So are a run of chapter 73 goods: sheet piling, railway track, tubes and pipes, fittings, structures, tanks and drums, gas containers, screws and bolts, and “other articles of iron or steel”[3]. If your product sits near an exception, read the CN code in Annex I before you assume you are out. The annex is the list. This paragraph is the map.

For those iron and steel codes, only direct emissions are counted. Indirect emissions from electricity used at the mill stay out. That is Annex II, read with Article 7(1)[3]. When you type a figure into the calculator, use direct embedded emissions for steel, not a footprint that includes the power plant.

Simplified 2026 certificate bill on an example 100-tonne shipment at the Q3 price of €82.32: €370.44. The 1.8 tCO2e per tonne is an example, not a default value.Example cost split, simplified 2026 reading100 tonnes × 1.8 tCO2e/t is an example you replace. It is not an EU default value.Free-allocation factor, 2026: 97.5%175.5 of the 180 tCO2e are the slice the simplified reading does not charge in 2026.You pay 2.5%: 4.5 certificates × €82.32 = €370.44Q3 2026 published price. Carbon already paid abroad in this picture: €0.00.The legal adjustment uses a CBAM benchmark × the CBAM factor × the CSCF, not this flat percentage.Electricity is different again: its free-allocation adjustment is zero.Open the certificate cost calculator and type your own tonnes, emissions and price.
Simplified 2026 certificate bill on an example 100-tonne shipment at the Q3 price of €82.32: €370.44

What this costs you

Example, not a typical mill: 100 tonnes, 1.8 tCO2e of direct emissions per tonne, imported in Q3 2026. The published price is €82.32[2]. The 2026 CBAM factor is 97.5%, so the simplified paid share is 2.5%[4]. The certificate line is €370.44 before any carbon price the producer already paid.

A real surrender can be higher or lower. Regulation 2025/2620 deducts a benchmark-based free allocation, not a flat 2.5% of whatever the mill emitted[6]. If the mill is dirtier than the EU benchmark, you pay on that gap as well as on the phased-in slice. We are not printing benchmark numbers here; they are product-specific and live in that regulation’s annex.

Scrap under heading 7204 is one of the explicit exceptions in Annex I[3]. Don’t stretch that into “recycled steel is exempt.” Downstream articles made from scrap can still be inside chapter 72 or 73. Check the code on the customs declaration.

Whether 100 tonnes even needs a declarant depends on the rest of the year. The 50-tonne threshold adds iron and steel together with aluminium, cement and fertilisers[3]. The threshold checker does that sum. The timeline shows when the simplified share stops being a sliver.

Sources

Every dated figure on this page is taken from the EU texts below. Where a shipment example uses 100 tonnes and 1.8 tCO2e per tonne, that pair is an illustration, not a published default. Law last checked 31 October 2026. See our methodology and editorial policy. General information, not legal, tax or customs advice.

  1. [1] European Commission: CBAM definitive regime (from 1 January 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en (checked 31 Oct 2026)
  2. [2] European Commission: Price of CBAM certificates (quarterly table): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en (checked 31 Oct 2026)
  3. [3] Regulation (EU) 2023/956, consolidated 20 October 2025 (CBAM Regulation): https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20/eng (checked 31 Oct 2026)
  4. [4] Directive 2003/87/EC, consolidated (EU ETS), Article 10a(1a) CBAM factor: https://eur-lex.europa.eu/eli/dir/2003/87 (checked 31 Oct 2026)
  5. [5] Commission Implementing Regulation (EU) 2025/2548 (certificate price method): https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R2548 (checked 31 Oct 2026)
  6. [6] Commission Implementing Regulation (EU) 2025/2620 (free-allocation adjustment): https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj/eng (checked 31 Oct 2026)
  7. [7] European Commission Guidance No. 4 on the free-allocation adjustment (CBAM factor table, including 2034 at 0%): https://taxation-customs.ec.europa.eu/document/download/3aa2c730-4f1b-4524-8f71-d9cfe4880ac7_en?filename=Guidance+No.+4+-+CBAM+calculation+of+the+free+allocation+adjustment+to+the+number+of+CBAM+certificates+to+be+surrendered.pdf (checked 31 Oct 2026)