Goods Covered Under CBAM
A full breakdown of which goods fall under the EU's Carbon Border Adjustment Mechanism (CBAM) in 2026 — covered sectors, CN codes, exemptions, and how to check if your imports are in scope.
A full breakdown of which goods fall under the EU's Carbon Border Adjustment Mechanism (CBAM) in 2026 — covered sectors, CN codes, exemptions, and how to check if your imports are in scope.
Since the EU's Carbon Border Adjustment Mechanism (CBAM) entered its definitive regime on 1 January 2026, one question sits at the top of every importer's checklist: is my product actually covered? Getting this wrong in either direction is costly — misclassifying an in-scope product as exempt risks penalties and unauthorised imports, while over-reporting wastes compliance resources on goods that were never in scope to begin with.
CBAM doesn't apply to "carbon-intensive imports" in a general sense. It applies to a specific, legally defined list of products identified by Combined Nomenclature (CN) codes, set out in Annex I of Regulation (EU) 2023/956. This guide walks through exactly which sectors and product categories are covered, what's excluded, and how the 50-tonne threshold works.
CBAM currently applies to six sectors, chosen because they combine high emissions intensity, exposure to international competition, and (in most cases) an existing EU ETS monitoring methodology that could be adapted for imports:
Iron and steel
Aluminium
Cement
Fertilisers
Electricity
Hydrogen
These are collectively referred to as CBAM goods, and the regulation's scope is defined by which specific CN codes fall under each sector — not by sector name alone. A product only counts as a CBAM good if its exact CN code appears in Annex I.
For a broader explainer on how this scope fits into the wider CBAM compliance timeline, see this Carbon Border Adjustment Mechanism (CBAM). (Note: that's a third-party Google Sites page rather than an EU government source — treat it as a supplementary explainer, and cross-check anything decision-critical against the official Commission page linked in the sources below.)
This is the widest-reaching CBAM sector. Coverage starts with primary materials — pig iron, ferro-alloys, and various forms of semi-finished and finished steel — but, uniquely among CBAM sectors, it also extends further downstream than the other categories. Certain fabricated steel articles, such as screws, bolts, and specific iron or steel articles, are included, not just raw steel. Scrap and remelted steel are generally excluded, since they don't represent new primary production emissions in the same way.
Covered greenhouse gas: carbon dioxide (CO₂).
Coverage spans unwrought aluminium, aluminium powders and flakes, bars, wire, plates, sheets, and a range of aluminium articles, including certain containers (e.g., CN code 7613 00 00 for aluminium containers for compressed or liquefied gas). Aluminium is one of the few CBAM sectors where two greenhouse gases are tracked, not just CO₂.
Covered greenhouse gases: carbon dioxide and perfluorocarbons (PFCs).
Cement coverage includes the intermediate product clinker (produced by heating limestone, and the single most emissions-intensive stage of cement production), along with finished cement types — Portland cement, aluminous cement, white Portland cement, and other hydraulic cements. Certain kaolinic clays used in cement production are also captured under the sector's CN codes.
Covered greenhouse gas: carbon dioxide (CO₂).
This sector covers nitrogen-based fertiliser inputs and products: ammonia, nitric and sulphonitric acids, urea, potassium nitrates, and various nitrogenous and mixed mineral/chemical fertiliser blends. Because fertiliser production involves nitrous oxide alongside CO₂, reporting requirements for several fertiliser CN codes explicitly include nitrous oxide data.
Covered greenhouse gases: carbon dioxide and nitrous oxide (N₂O).
Electricity is covered as a single CN code (2716 00 00 – electrical energy) but is treated differently from the other five sectors in one important respect: it has no minimum quantity threshold. Any volume of imported electricity falls under CBAM, reflecting how directly electricity generation emissions can be measured and how sensitive the sector is to carbon leakage through cross-border power trading.
Covered greenhouse gas: carbon dioxide (CO₂).
Like electricity, hydrogen has no de minimis threshold — any imported quantity is in scope. As demand for "clean" and "low-carbon" hydrogen grows, this sector is expected to see close regulatory attention as trade volumes increase.
Covered greenhouse gas: carbon dioxide (CO₂).
CBAM doesn't just define which products are covered — it also defines which emissions count for each one:
Direct emissions — released during the actual production process — are counted for all six sectors.
Indirect emissions — from the electricity consumed during production — are counted for cement and fertilisers during the definitive period. For sectors covered by the EU ETS's indirect cost compensation scheme, only direct emissions are counted, to avoid double-counting a cost already priced in elsewhere.
This distinction matters for cost forecasting: two products with identical direct emissions can carry very different total CBAM exposure depending on whether indirect electricity emissions are also in scope.
Under the 2026 simplification (introduced via the Omnibus package), a unified 50-tonne annual threshold applies across cement, iron and steel, aluminium, and fertilisers. If an importer brings in less than 50 tonnes of CBAM goods, combined across those four sectors, in a calendar year, they are exempt from CBAM's authorisation and reporting obligations.
Two details are easy to miss here:
The 50-tonne threshold is calculated on the total combined quantity of CBAM goods an importer brings in that year — not on each product separately.
Electricity and hydrogen are excluded from the threshold entirely. Any volume of either, however small, keeps an importer in scope.
According to industry estimates, this exemption removes the vast majority of small-volume importers from CBAM's administrative burden, while the goods that remain in scope still represent close to the overwhelming share of total embedded emissions covered by the mechanism — since larger, high-volume importers were always the intended target.
Find your product's CN code. This eight-digit Combined Nomenclature code appears on your customs declarations and commercial invoices.
Check it against Annex I of Regulation (EU) 2023/956. This is the definitive list — sector name alone isn't enough, since fabrication level and product form can push a good in or out of scope.
Watch classification boundaries. Heavily fabricated steel products may fall outside the steel CN codes; cement-containing construction products may be classified separately from raw cement. When in doubt, the CN code — not the general product description — is what determines coverage.
Check your annual import volume against the 50-tonne threshold, remembering that electricity and hydrogen bypass the threshold altogether.
If you're unsure how your product is classified, a CBAM software platform or customs/trade compliance advisor can cross-check your CN codes against Annex I far faster than doing it manually line by line — see our companion guide on choosing the right CBAM reporting software for how these tools handle scoping.
CBAM's scope isn't static. Article 30 of the regulation requires the European Commission to report by 2028 on potential expansion, with organic chemicals, polymers, and additional downstream products already flagged as likely candidates. Downstream expansion is considered more complex to implement because it requires emissions data from many more suppliers further down increasingly fragmented supply chains — but it signals that today's scope is a starting point, not a permanent boundary.
Does CBAM cover finished consumer goods made from steel or aluminium, like appliances or vehicles? Generally, no — CBAM's downstream coverage in the steel and aluminium sectors is limited to specific listed articles (such as certain fasteners), not general finished consumer products. Most manufactured goods sit outside current CBAM scope, though this could change with future expansions.
Is scrap metal covered under CBAM? No. Scrap and remelted steel are generally excluded, since they don't represent new primary-production emissions in the way virgin material production does.
Does the 50-tonne threshold apply per shipment or per year? Per calendar year, per importer, combined across cement, iron and steel, aluminium, and fertiliser imports — not per shipment and not per individual product line.
Are electricity and hydrogen imports really covered no matter how small? Yes. Unlike the other four sectors, electricity and hydrogen have no minimum quantity exemption under CBAM.
CBAM's product scope is precise by design: six sectors, defined down to the CN code, with specific rules on which greenhouse gases and which emissions (direct vs. indirect) count for each. Before assuming your imports are — or aren't — covered, check the actual CN code against Annex I rather than relying on the sector name alone, and keep the 50-tonne threshold and its electricity/hydrogen exception in mind when assessing your obligations for the year ahead