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Lakshmikumaran and Sridharan attorneysNavigating CBAM

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How does CBAM apply to iron and steel imports?

Iron and steel goods covered by CBAM: primary and downstream lines, BF-BOF vs EAF routes, scrap deduction and the move to verified actual emissions.

By Lakshmikumaran and Sridharan attorneysReviewed by LKS CBAM editorial team
Last reviewed: June 2026
On this page
  1. Direct answer
  2. What is covered
  3. BF-BOF vs EAF: the route gap
  4. Scrap, mass balance and the no-double-counting rule
  5. Downstream products: tubes, fittings, structures
  6. Direct and indirect emissions
  7. Where the numbers come from
  8. FAQ
  9. What to read next

Direct answer

Iron and steel is the broadest CBAM sector, with roughly 480 CN codes in Annex I covering pig iron and DRI, crude steel, semi-finished products, flat and long rolled products, tubes, tubes fittings and selected downstream articles. Embedded emissions depend sharply on the production route: integrated BF-BOF (blast furnace, basic oxygen furnace) sits at the high end; EAF (electric arc furnace) using scrap or DRI sits well below. From 2026 verified actuals from the producing installation are the expected input, with default values as fallback.

What is covered

Annex I lists Chapter 72 (iron and steel) products plus selected lines from Chapter 73 (articles of iron or steel) including tubes, pipes, fittings, structures, fasteners and tanks. The full set is below; the covered-goods checker resolves a single code.

479 CN codes in 8 sub-groups (Annex I, DG TAXUD)

Iron and steel: process schematic

Sources

BF-BOF and EAF routes have very different intensities; precursors (pig iron, DRI, scrap) aggregate into the downstream good.

Implementing Regulation (EU) 2023/1773, Annex IV; sectoral communication template (iron and steel)

BF-BOF vs EAF: the route gap

The integrated BF-BOF route produces hot metal in the blast furnace using coke as both reducing agent and energy source, then converts to crude steel in a basic oxygen furnace. Direct emissions sit around 1.8-2.2 tCO2 per tonne of crude steel. The EAF route remelts ferrous scrap (and sometimes DRI/HBI) using electric power; direct emissions drop to roughly 0.3-0.6 tCO2/t but indirect emissions from electricity become the dominant share. DRI-EAF using natural gas reformation sits between the two; DRI-EAF using hydrogen approaches the renewable-electrolytic limit. The route the installation runs is the single biggest driver of the embedded total.

Scrap, mass balance and the no-double-counting rule

Ferrous scrap (CN 7204) is not in Annex I and is out of scope. Steel produced from scrap inherits no embedded emissions from the scrap input itself, on the principle that those emissions were attributed to the original primary steel cycle. The installation methodology treats scrap as a zero-emission input for embedded-emissions purposes. Plants that combine primary hot metal with scrap apply a mass-balance attribution between the two charge sources.

Downstream products: tubes, fittings, structures

The downstream lines in Chapter 73 (tubes and pipes, fittings, structures, fasteners, containers) inherit the embedded emissions of the primary steel input plus the fabrication step at the installation. Fabrication adds relatively little to the per-tonne intensity; the upstream steel route still dominates. Downstream installations rely on the steelmaker's verified data for the input share.

Direct and indirect emissions

Direct emissions cover combustion at the installation (coke ovens, sinter plant, blast furnace, BOF, reheat furnaces, EAF arcing combustion of electrodes), plus process emissions from reduction reactions and from lime calcination in metallurgical use. Indirect emissions from purchased electricity are material for EAF plants and for downstream rolling and finishing. The treatment of indirect emissions follows the regulation; during the transition they are reported; under the definitive regime the treatment converges with EU ETS practice.

Where the numbers come from

Verified actual emissions from the producing installation are the preferred input. The installation methodology sets the boundary, monitoring approach and verification scope. Where actuals are not available, the published default values apply.

Loading default values dataset...

Frequently asked questions

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Source: Navigating CBAM by Lakshmikumaran and Sridharan Attorneys. Canonical: https://cbam.lkslaw.com/sectors/iron-and-steel (ref 02isk53). Reuse permitted under the site terms with attribution and a link back.

Discuss this topic with our international trade and customs practice: write to ankur.sharma@lakshmisri.com.