Covered goods and CN codes

The six sectors covered by CBAM

Annex I of Regulation 956/2023 exhaustively defines the goods subject to CBAM through their Combined Nomenclature (CN) codes. Six sectors are covered, selected for their carbon intensity and their exposure to carbon leakage risk.

1. Cement

Cement is one of the most CO2-emitting materials in the world. The clinker production process (the main component of cement) generates substantial direct emissions (calcination of limestone + combustion).

Covered CN codes:

• 2507 00 80 -- Kaolinic clays and others (excluding kaolin)
• 2523 10 00 -- Cement clinkers
• 2523 21 00 -- White Portland cement
• 2523 29 00 -- Other Portland cement
• 2523 30 00 -- Aluminous cement
• 2523 90 00 -- Other hydraulic cements

Typical emissions: 0.6 to 0.9 tonnes of CO2 per tonne of cement produced. The majority of emissions (approximately 60%) come from the calcination process -- a chemical reaction inherent to clinker production that cannot be eliminated without fundamentally changing the product.

Key import flows into the EU: Turkey, Morocco, Tunisia, Algeria, and the Western Balkans are the primary sources of cement imports. Turkey alone accounts for over 40% of EU cement imports by volume.

2. Iron and steel

The steel sector is the second largest industrial CO2 emitter in the EU. CBAM coverage is very broad, ranging from raw products (pig iron, crude steel) to semi-finished and finished products.

Covered CN codes (main extracts):

• 7201 -- Pig iron and spiegeleisen
• 7202 -- Ferro-alloys
• 7203 -- Ferrous products obtained by direct reduction
• 7204 -- Ferrous waste and scrap
• 7205 to 7229 -- Flat-rolled, bars, angles, shapes, wire, tubes in steel
• 7301 to 7326 -- Structures, reservoirs, cables, miscellaneous articles of iron or steel
• 7301 -- Sheet piling
• 7302 -- Railway track elements
• 7303 to 7307 -- Tubes and pipes
• 7308 -- Structures and parts of structures
• 7309 to 7326 -- Reservoirs, cables, miscellaneous manufactured articles

Typical emissions:

• Blast furnace route (BF-BOF): 1.4 to 2.2 tonnes CO2 per tonne of steel
• Electric arc furnace route (EAF): 0.3 to 0.5 tonnes CO2 per tonne

This 3-5x differential between production routes has major implications for CBAM cost. EAF steel, primarily made from recycled scrap, carries a structural advantage under the mechanism.

Key import flows: Turkey (largest EU steel supplier, ~15 Mt/year), India, China, South Korea, Ukraine, and Russia (pre-sanctions).

3. Aluminium

Primary aluminium is an extremely energy-intensive metal whose production through electrolysis generates significant direct and indirect emissions.

Covered CN codes:

• 7601 -- Unwrought aluminium
• 7602 -- Aluminium waste and scrap
• 7603 -- Aluminium powders and flakes
• 7604 -- Aluminium bars, rods, and profiles
• 7605 -- Aluminium wire
• 7606 -- Aluminium plates, sheets, and strips
• 7607 -- Aluminium foil
• 7608 -- Aluminium tubes and pipes
• 7609 to 7616 -- Pipe fittings, structures, manufactured articles

Typical emissions: 8 to 18 tonnes of CO2 per tonne of primary aluminium (highly dependent on the electricity mix of the producing country). A smelter powered by hydroelectricity in Norway or Iceland emits approximately 2-4 tCO2/t, while a coal-powered smelter in China or India can exceed 18 tCO2/t.

Key import flows: Russia (pre-sanctions), China, India, Norway (non-EU but linked ETS), UAE, Bahrain, Mozambique.

4. Fertilisers

Nitrogen fertilisers are covered due to emissions from ammonia production (steam methane reforming of natural gas) and nitric acid production.

Covered CN codes:

• 2808 00 00 -- Nitric acid; sulphonitric acids
• 2814 -- Anhydrous ammonia or in aqueous solution
• 2834 -- Nitrites and nitrates
• 3102 -- Mineral or chemical nitrogenous fertilisers
• 3105 -- Fertilisers containing nitrogen with phosphorus and/or potassium

Typical emissions: 1.6 to 2.7 tonnes of CO2 per tonne of ammonia. The production of ammonia through steam methane reforming accounts for approximately 1.8% of global CO2 emissions.

Key import flows: Russia, Trinidad and Tobago, Algeria, Egypt, United States, Saudi Arabia.

5. Electricity

Electricity is included in CBAM to prevent carbon leakage in electrical interconnection zones with the EU.

Covered CN code:

• 2716 00 00 -- Electrical energy

Specificity: Only direct emissions are taken into account. Electricity imports from third countries whose electricity market is coupled with that of the EU (Norway, Switzerland under certain conditions) may benefit from specific provisions. The emissions factor for imported electricity is typically based on the average grid emission factor of the exporting country, unless specific data from the generating installation is available.

Key flows: Ukraine, Western Balkans, Morocco, Turkey (interconnected grids).

6. Hydrogen

Hydrogen was added to cover a rapidly growing sector where the risk of future carbon leakage is anticipated.

Covered CN code:

• 2804 10 00 -- Hydrogen

Typical emissions by production method:

The enormous range (0.5 to 12 tCO2/t) makes actual emissions data critical for hydrogen imports. Using default values for green hydrogen would result in dramatically overstated costs.

De minimis threshold

Article 2a of Regulation 956/2023, amended by Regulation 2025/2083, provides a de minimis exemption:

Shipments with an intrinsic value not exceeding EUR 150 or a gross weight not exceeding 50 kg are exempt from CBAM, provided the consignor does not send more than 50 tonnes of CBAM goods in total per year into the EU.

Article 25a provides a monitoring mechanism for compliance with this threshold. The 50-tonne limit applies across all CBAM goods combined, not per product. It is calculated at the consignor level, not the importer level.

Practical implication: small and medium importers with modest volumes may find themselves exempt. However, if the annual total crosses the 50-tonne threshold even once, the full CBAM obligations apply retroactively for the entire calendar year.

How to check if a product is covered

Step 1: Identify the CN code

The 8-digit CN code of your goods is the determining element. Use our automated classification tool or consult the TARIC nomenclature to identify the exact code. Accurate tariff classification is essential -- a single digit difference can mean the product falls inside or outside CBAM scope.

Step 2: Check against Annex I

Compare the identified CN code with the list in Annex I of Regulation 956/2023. Note that some CN codes are covered at the heading level (4 digits), others at a more detailed level (6 or 8 digits). When a heading is listed, all sub-headings within it are covered unless explicitly excluded.

Step 3: Verify exclusions

Certain products are explicitly excluded even if their CN code is covered:

• Goods in transit through the EU customs territory
• Returned goods (reimportation) under the same CN code
• Goods under inward processing regime, if re-exported (Art. 34)
• Goods originating in Iceland, Liechtenstein, Norway, or Switzerland (countries linked to the EU-ETS or with equivalent carbon pricing)

Direct vs indirect emissions coverage by sector

CBAM covers:

• Direct emissions: emissions produced during the manufacturing process (always covered for all sectors)
• Indirect emissions: emissions related to the electricity consumed during manufacturing (covered for certain sectors only)

The exclusion of indirect emissions for iron/steel and aluminium is a temporary measure. The Article 30 review may extend indirect emissions coverage to these sectors.