The European Union's Carbon Border Adjustment Mechanism (CBAM) moved from its transitional period to its definitive period on 1 January 2026. Iron and steel products are at the heart of the mechanism, and the scope is not limited to crude steel: steel structures and certain welded products are also among the goods subject to CBAM.
For companies exporting steel structures, chassis, platforms or similar welded products to the EU, this means requests from customers for embedded emissions data are now becoming routine.
What Is CBAM and Who Does It Affect?
CBAM puts a price on the carbon emissions generated in producing certain goods imported into the EU. Its aim is to create a level playing field between EU producers covered by the EU Emissions Trading System (ETS) and imported goods. The sectors in scope are iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
- Obligated party: The importer in the EU (authorised CBAM declarant).
- Data provider: The producer outside the EU — that is, the exporting Turkish company and its supply chain.
Important: If the importer cannot provide verified actual emissions data, it must use default values set by the EU. Default values are usually higher than actual values and increase costs. This gives suppliers who can provide data a competitive edge.
Timeline: From the Transitional to the Definitive Period
| Period | Obligation |
|---|---|
| October 2023 – December 2025 | Transitional period: quarterly reporting, no financial obligation |
| 1 January 2026 | Definitive period began: only authorised declarants may import |
| 2027 | Sale of CBAM certificates and first annual declaration for 2026 imports |
| 2026 – 2034 | CBAM burden increases as EU ETS free allocations are gradually phased out |
Under the simplification package adopted at the end of 2025, small importers bringing in less than 50 tonnes a year were exempted. However, since most of your major customers will remain above this threshold, demand for data will not decrease.
Note: The CBAM timeline and implementation rules may be updated by the EU. This article is for general information only; for current obligations, follow official sources and your customs broker.
Are Welded Fabrication Products in Scope?
CBAM scope is defined by Combined Nomenclature (CN) codes. Under the iron and steel heading, in addition to flat and long products, many articles in Chapter 73 are also included — for example, steel structures and parts of structures under heading 7308 (bridge sections, towers, lattice structures, platforms, etc.). Whether your product is in scope must be checked item by item against its CN code.
How Are Embedded Emissions Calculated?
The embedded emissions of a welded steel product consist of two main components:
- Emissions from precursor materials: Emissions from producing the sheet, sections and tubes used. This data comes from the steel producer (your supplier) and makes up most of the total.
- Emissions from your own process: Direct and indirect emissions from the fuel and electricity used in cutting, welding, heat treatment and painting.
The first step in CBAM preparation is therefore to request product-level emissions data from your steel suppliers and to be able to match this data to batch numbers.
Preparation Steps for Exporters
- Compare the CN codes of the products you sell to the EU against the CBAM annex list.
- Request installation- and product-level emissions data from your steel suppliers.
- Set up a metering infrastructure that can allocate your plant's energy and fuel consumption to product groups.
- Link material traceability (EN 10204 3.1 certificate – batch – product) digitally.
- Keep your records auditable so the data is ready for independent verification.
Material and batch traceability is already part of EN ISO 3834-2 and EN 1090 systems. Companies with this infrastructure in place start CBAM data preparation with a significant advantage.
Frequently Asked Questions
When did the CBAM definitive period begin?
The CBAM definitive period began on 1 January 2026. From that date, only authorised CBAM declarants may import goods in scope into the EU.
Are steel structures covered by CBAM?
Yes, steel structures and parts of structures under CN heading 7308 are among the iron and steel products covered by CBAM. Each product should be checked against its CN code.
Who pays the CBAM charge?
The CBAM obligation lies with the importer in the EU. However, the importer has to obtain actual emissions data from the producer outside the EU; suppliers who cannot provide data become more expensive because of default values.
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