CBAM Affected Products: The Current In-Scope List

The EU Carbon Border Adjustment Mechanism (CBAM) puts a carbon price at the EU border for imports in six emissions-intensive sectors. It is already live in reporting form and moves to full financial liability from January 2026. This guide covers the exact scope, the data requirements, and how the cost is calculated once you become an authorised CBAM declarant.

The six sectors currently in scope

• Cement - clinker, portland cement, aluminous cement, other hydraulic cements.
• Electricity - imported into the EU synchronous area.
• Fertilisers - nitric acid, ammonia, urea, mixed fertilisers, potassium nitrate.
• Iron & steel - pig iron, semi-finished products, flat and long products, tubes and pipes, plus selected downstream articles (screws, bolts, structures).
• Aluminium - unwrought aluminium, powders, bars, rods, plates, sheets, tubes and pipes, structures.
• Hydrogen - all forms.

Annex I of Regulation 2023/956 lists every in-scope CN code. Expansion to organic chemicals, polymers and refined petroleum products is scheduled for review before the end of the decade.

Transitional vs definitive period

• 1 October 2023 - 31 December 2025 (transitional): Quarterly reports with embedded emissions in tonnes CO2e. No financial obligation. Reports submitted via the CBAM Registry within one month of quarter end.
• From 1 January 2026 (definitive): Only authorised CBAM declarants can import. Annual CBAM declaration by 31 May of the following year. Surrender CBAM certificates equal to embedded emissions minus any carbon price already paid abroad. Certificates priced at average weekly EU ETS clearing price.

Calculating embedded emissions

Two components:

• Direct emissions - from the production process itself, including emissions from precursor materials consumed in production.
• Indirect emissions - from electricity used in production. Currently mandatory only for cement and fertilisers; likely to expand.

Actual emissions from the installation, verified by an accredited verifier, are the preferred method. When actual data is not available, Commission-published default values apply - and defaults are set at the 90th percentile of the exporting country's emissions distribution, which almost always exceeds any specific installation's actual footprint. That built-in penalty is the mechanism forcing producers to provide verified data.

Cost impact worked

Import of 1,000 tonnes of primary aluminium with embedded emissions of 15 tCO2e/t (a typical coal-power source), certificate price of EUR 80/tCO2e, no carbon price in the country of production:

• Embedded emissions = 1,000 × 15 = 15,000 tCO2e
• CBAM certificate cost = 15,000 × 80 = EUR 1.2m

For a shipment worth roughly EUR 2.5m at 2025 prices, that is a 48 percent uplift. Low-carbon aluminium from hydro-powered smelters (with embedded emissions closer to 4 tCO2e/t) faces a proportionally smaller CBAM cost, which will drive procurement decisions toward verified low-carbon suppliers.

How to prepare

1. Identify in-scope imports. Check every Annex I CN code against your import volumes.
2. Request emissions data from suppliers. Structured template published by the Commission. Push for verified numbers - defaults will be materially worse.
3. Apply for CBAM declarant authorisation. Application via the relevant national competent authority. Non-EU importers need to appoint an indirect customs representative.
4. Model the cost. Build CBAM certificate cost into landed-cost pricing before contracting for 2026 shipments.

Related commodity guides

Sector-specific detail lives in the HS guides for iron and steel, aluminium, cement, cement clinker, fertilisers, hydrogen and electricity. Use the Import Duty Calculator to combine duty with the CBAM certificate cost for full landed pricing.