Fifty tonnes. That’s the annual import volume that puts you inside CBAM’s definitive regime — roughly two truckloads of structural steel. If you fabricate, distribute, or build with steel in Ireland and any of it originates outside the EU, you are almost certainly over the line, and the obligations that follow are not paperwork you can leave to your customs agent.
CBAM covers most iron and steel goods in CN chapters 72 and 73 — from pig iron and semi-finished billets through to structural sections, tubes, screws and bolts. Since 1 January 2026, importers bringing in more than 50 tonnes of CBAM goods per year need authorised CBAM declarant status, must calculate the direct embedded emissions in their steel, and will surrender CBAM certificates for the first time in 2027. The first annual declaration, covering 2026 imports, is due by 30 September 2027.
Key Takeaways
- The exemption threshold is 50 tonnes per year across all your CBAM goods combined — a level most steel buyers pass in a single order
- Coverage spans most of CN chapters 72 and 73, including fasteners (7318) and other articles of steel (7326) that many importers don’t expect
- For steel, the certificate obligation is calculated on direct emissions only — production-route differences (BOF vs EAF) still drive the numbers
- CBAM follows the origin of the goods, not the seller — steel bought from a UK stockholder is in scope if it originated outside the EU
- Only 2.5% of embedded emissions attract certificates in 2026, but the CBAM factor climbs to 100% by 2034 — today’s small bill is a preview, not the price
Two Truckloads and You’re In
The old €150-per-consignment exemption is gone. Under the simplification package adopted in October 2025 (Regulation (EU) 2025/2083), a single mass-based threshold applies: import more than 50 tonnes of CBAM goods in a calendar year — steel, aluminium, cement and fertilisers counted together — and the full regime applies to you.
For steel buyers this threshold is close to meaningless as a shelter. A modest fabrication job can consume 50 tonnes of sections and plate. Once you expect to cross it, you need authorised CBAM declarant status before you do. Importers who applied by 31 March 2026 were allowed to keep importing while their application was processed; if you are importing above the threshold today without authorisation or a pending application, that is an exposure to deal with now — see our guide to CBAM registration in Ireland, or talk to us about regularising your position.
What Chapters 72 and 73 Actually Catch
CBAM’s steel scope is defined by CN code, and it is wider than most importers assume. It runs from raw and semi-finished material — pig iron, billets, slabs — through flat and long products, tubes and pipes, and into fabricated and downstream goods, notably:
- Structures and parts of structures (7308) — the bread and butter of every EN 1090 fabrication shop: welded sections, plate girders, towers, lattice masts
- Screws, bolts, nuts and similar articles (7318) — high-volume, low-unit-value goods where nobody was tracking embedded carbon
- Other articles of iron or steel (7326) — a catch-all heading that pulls in a long tail of steel products
The notable exclusions are ferrous waste and scrap (heading 7204) and certain ferro-alloys. Everything else needs checking line by line against Annex I of the regulation — and misclassification cuts both ways: missed reporting obligations on one side, unnecessary compliance costs on the other. A Commission proposal published in December 2025 would extend the scope to further downstream steel products, so the boundary is moving, not settled.
Two scope points matter enormously for Irish buyers:
Origin, not invoice. CBAM applies based on where the goods originated, not who sold them to you. Steel of Chinese, Turkish or Indian origin bought through a UK stockholder and shipped into Ireland is fully in scope — the UK invoice changes nothing. Given how much Irish steel supply routes through Britain, plenty of importers have CBAM exposure they haven’t identified.
A short exempt list. Goods originating in Iceland, Norway, Switzerland and Liechtenstein are outside CBAM, because those countries run or are linked to the EU ETS. No other origin is exempt.
If you’re new to the mechanism itself, start with our plain-English explainer on what CBAM is and how it works.
Direct Emissions Only — and Why the Production Route Still Decides Your Bill
Iron and steel sit in Annex II of the CBAM Regulation, which means the certificate obligation is calculated on direct emissions only — the CO2 released in the production process itself, plus embedded emissions from precursors like pig iron and crude steel. Indirect emissions from purchased electricity, which had to be reported during the 2023–2025 transitional period, do not currently attract certificates for steel.
That makes the production route the dominant variable. Blast furnace–basic oxygen furnace (BF-BOF) steel, made from ore and coke, carries several times the direct emissions of electric arc furnace (EAF) steel made from scrap. But real supply chains rarely resolve to a clean either/or: mills blend scrap with virgin material, semi-finished products carry precursor emissions from other installations, and downstream processing adds stages that each need correct treatment under the EU methodology — system boundaries, precursor attribution and production-route rules that go far beyond picking BOF or EAF from a dropdown. This is where we spend most of our time with steel clients, because errors here flow straight into the declaration you sign.
What It Costs: the Phase-In Most Cost Models Miss
Two moving parts set your certificate bill: the EU ETS carbon price and the CBAM factor — the share of embedded emissions that actually requires certificates as free allocation to EU steelmakers is withdrawn.
| Year | CBAM factor (share of emissions requiring certificates) |
|---|---|
| 2026 | 2.5% |
| 2027 | 5% |
| 2028 | 10% |
| 2029 | 22.5% |
| 2030 | 48.5% |
| 2034 | 100% |
In 2026 the cash cost is small — a fortieth of the full exposure. By 2030 nearly half of your steel’s embedded emissions are billable, and by 2034 all of them are. Certificate sales open on 1 February 2027, priced off the average 2026 ETS auction price, with the first surrender due alongside the 30 September 2027 declaration. A supplier decision that looks cost-neutral today can carry a steep, predictable escalation built into it — which is why we model client exposure across the full phase-in, not just the current year. Our guide to CBAM certificates covers the mechanics.
Default Values Are Designed to Cost You More
If you can’t obtain compliant emissions data from your supplier, you fall back on default values — and under the 2025 rules, defaults are set from the average emission intensity of the ten highest-emitting exporting countries for each product. They are built to overstate the emissions of any reasonably efficient mill, deliberately, so that actual data is always worth pursuing.
Getting that data is the hard part. Non-EU mills have no obligation to hand over installation-level emissions figures, and what they do provide frequently uses the wrong system boundaries, omits precursors, or can’t survive verification. Multi-stage supply chains — billet from one country, rolling in a second, galvanising in a third — multiply the problem. Structured supplier engagement, run by people who know both the regulation and the steel industry, is what closes the gap; ad hoc email requests to a mill’s sales office do not.
What This Means for Procurement
From 2026 onwards, a steel quote without emissions data attached is an incomplete price. A supplier €50/tonne cheaper on invoice can be dearer in total once their emissions intensity and the rising CBAM factor are priced in — and locking into that supplier now means carrying the differential all the way up the phase-in curve to 2034. Contracts need emissions-data clauses; supplier evaluation needs a carbon column; and someone needs to own the annual declaration those numbers feed. See our procurement compliance service for how we embed this.
Where Clearscope Comes In
Steel CBAM sits across customs classification, carbon accounting and commercial negotiation, and mistakes in any one of them surface as enforcement exposure or overpayment. Our CBAM compliance service handles the parts that go wrong most often:
- Scope and classification review — confirming which of your products fall under chapters 72 and 73, including origin analysis for UK-routed supply
- Emissions quantification and supplier data programmes — replacing punitive defaults with verified installation-level data
- Exposure modelling across the 2026–2034 phase-in — so sourcing decisions reflect the real cost curve
- Declarant authorisation and annual declarations — keeping you compliant as the regime tightens
Importing aluminium or cement alongside steel? The rules differ more than you’d expect — see our guides for aluminium importers and cement importers. Or get in touch for a steel-specific CBAM assessment.
Frequently Asked Questions
Does CBAM apply to steel I buy from a UK distributor?
It depends on the origin of the steel, not the seller. Steel of non-EU origin — Chinese, Turkish, Indian or UK-produced — imported into Ireland is in scope even when purchased through a British stockholder. Establishing origin correctly across a distributor's mixed inventory is one of the first things we check for Irish clients.
Are bolts, screws and fasteners covered by CBAM?
Yes. Heading 7318 — screws, bolts, nuts and similar articles — is within CBAM scope, which surprises many importers because the unit values are small. The 50-tonne threshold applies to your combined CBAM imports, so fastener volumes count towards it.
Is scrap-based (EAF) steel exempt from CBAM?
No — all covered steel products are in scope regardless of production route. But because the obligation is calculated on direct emissions, EAF steel typically carries a far smaller certificate cost than blast-furnace steel. Ferrous scrap itself (heading 7204) is excluded.
What do I owe for my 2026 steel imports, and when?
Your first annual CBAM declaration, covering goods imported during 2026, is due by 30 September 2027, with certificates surrendered against 2.5% of embedded emissions. Certificate sales open on 1 February 2027. The low first-year percentage is temporary — the factor reaches 100% by 2034.