CBAM, the EU Carbon Border Tax: Is Your HS Code on the List?

Timeline

• 2026-01-01Definitive period begins: EU importers need "authorised CBAM declarant" status to import covered goods
• 2027-09-30First annual declaration due (covering 2026 import volumes and embedded emissions)
• 2028-01-01Proposed: extension to about 180 downstream steel and aluminium products (COM(2025) 989, not yet adopted; the European Parliament's Environment Committee wants 277)

Industries affected

Screws, nuts and fasteners

All of HS 7318 is covered — the largest category of Taiwanese steel products shipped to the EU.

Aluminium extrusions, tubes and sheet

Aluminium materials and semi-finished goods such as 7604, 7606 and 7608 are on the list.

Steel tubes, structures and containers

7304–7311 are covered.

Hardware, stampings, castings and forgings

Covered if classified under 7326 "other articles of iron or steel" or 7616 "other articles of aluminium"; the 2028 proposal adds 7325 cast articles, 7320 springs and 7317 nails.

Auto parts, metal furniture, motors, cables

Not covered today, but the 2028 extension proposal names 8708 gearboxes, wheels and suspension, plus 9403 metal furniture, 8501 motors and 8544 cables.

Bicycle parts, hand tools, machinery

Neither the current list nor the 2028 proposal includes 8712, 8714 or chapter 82 — but the steel and aluminium they are made from are already covered, and the scope widens with every round.

CBAM covered HS codes

Compiled from Annex I of Regulation (EU) 2023/956 (consolidated version of 2025-10-20). Finished-product HS codes not on this list are currently out of scope — for example bicycle parts (8714) and hand tools (Chapter 82).

Exclusions in Chapter 72: 7202 27202 307202 507202 707202 807202 917202 927202 937202 997204 (certain ferro-alloys and scrap); fertiliser exclusion: 3105 60.

HS codes added by the 2028 extension proposal (not yet adopted)

On 17 December 2025 the European Commission proposed COM(2025) 989 to bring about 180 downstream steel and aluminium products into scope, expected to apply from 1 January 2028. Entries marked “ex” cover only the part containing steel or aluminium. The final list may still change.

What your EU buyer will ask for

• The embedded emissions of every shipment (supplied by you, the non-EU producer — the importer cannot calculate this on their own)
• Production installation data: site, production process, and where your input materials come from
• Buyers importing less than 50 tonnes a year in total are exempt from declaring — if your volumes are small, first ask your buyer whether they go over that

What to do now

1. Confirm your HS code first. The same product declared under 7326 or under a finished-goods code gets a completely different result — check the exact 8-digit code you use with your customs broker.
2. Ask your EU buyer two things: does he import more than 50 tonnes of covered goods a year (if not, he is exempt), and has he applied for authorised CBAM declarant status?
3. Start keeping production records: electricity, fuel, and the source and quantity of raw materials (steel billet, aluminium ingot) for each process. Without actual data the buyer has to use EU default values, which are deliberately set high.
4. Ask your suppliers for data: the emissions of the steel and aluminium you buy must come from the mills, and this part is usually the largest share.
5. Emissions data must be verified by an EU-accredited verifier, so learn the process early. Factories can also register themselves in the EU CBAM Registry, so data entered once can be shared with several buyers.

FAQ