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Import guide
EU CBAM guide for buyers of steel and aluminum parts
The EU Carbon Border Adjustment Mechanism, set up by Regulation (EU) 2023/956, covers imported iron, steel and aluminum goods including articles under CN 7318, 7326 and 7616, but not 8538 or 8708. Its definitive period began on 1 January 2026. After the 2025 simplification, importers below 50 tonnes a year are exempt. Check current rules before import.
What is CBAM and when does it apply?
CBAM puts a carbon price on the emissions embedded in certain imported goods, so that EU importers pay a price comparable to EU producers under the EU Emissions Trading System. It is set up by Regulation (EU) 2023/956.
A transitional period ran from 1 October 2023 to 31 December 2025, during which importers filed quarterly reports on embedded emissions but paid nothing. The definitive period began on 1 January 2026: importing CBAM goods above the threshold requires the status of authorized CBAM declarant, an annual CBAM declaration, and the purchase and surrender of CBAM certificates.
Are your metal parts in scope?
Scope follows the Combined Nomenclature (CN) code listed in Annex I of the regulation. For iron and steel the annex lists most of Chapter 72 plus specific Chapter 73 headings; for aluminum, specific Chapter 76 headings.
| CN heading | Typical parts | In CBAM scope? |
|---|---|---|
| 7318 | Screws, bolts, nuts, washers and similar steel fasteners | Yes |
| 7326 | Other articles of iron or steel: brackets, covers, enclosures | Yes |
| 7308 | Steel structures and parts of structures | Yes |
| 7616 | Other articles of aluminum | Yes |
| 7610 | Aluminum structures and parts of structures | Yes |
| 7320 | Springs of iron or steel | No (not listed in Annex I) |
| 8538 | Parts for electrical switchgear and control panels | No |
| 8708 | Parts of motor vehicles | No |
| Copper alloys (Chapter 74) | Nickel-silver shields, copper terminals | No |
What did the 2025 simplification change?
Regulation (EU) 2025/2083 amended the CBAM regulation. The change most relevant to small buyers is a mass-based de minimis threshold: an importer whose combined imports of iron and steel, aluminum, cement and fertilizer goods stay below 50 tonnes per calendar year is exempt from CBAM obligations. It replaced the earlier low-value exemption per consignment.
The amendments also adjusted administrative steps such as declaration and certificate timelines. Because these details are still being implemented through further acts and guidance, confirm the current deadlines with the European Commission’s CBAM pages or your customs adviser before you import.
Who is responsible for CBAM — the buyer or the supplier?
The obligations sit with the EU side: the importer or an indirect customs representative must be an authorized CBAM declarant, file the declaration and surrender certificates. A non-EU supplier has no CBAM filing of its own, but its data decides whether the importer can use actual emissions or must fall back on default values published by the Commission.
Classification is also the importer’s decision. The same part can be 7326 or 8538 depending on its function, and only one of those is in scope. See our guide to HS codes for enclosures.
What data can a Chinese supplier provide?
| Data item | Why the importer needs it | What we can provide |
|---|---|---|
| Net mass per part and per shipment | CBAM quantities are declared in tonnes | Yes, from our weights and packing lists |
| Steel or aluminum content | Separates CBAM metal from plastic or other parts in an assembly | Yes, from the bill of materials |
| Material grade and mill certificate | Identifies the precursor (coil or sheet) and its producer | Yes, from the material supplier’s mill certificate |
| Production route | Embedded emissions depend on how the goods are made | Yes: purchased coil or sheet, then stamping, laser cutting, bending or welding; finishing by partners |
| Installation information | Name, address and location of the production site | Yes: our Suzhou factory |
| Emissions data (direct, indirect, precursors) | Needed to use actual instead of default values | We support data requests; we do not currently hold verified emissions data |
Practical steps for EU buyers
- List the CN codes of the parts you import and confirm classification with your customs adviser.
- Add up your annual tonnage of CBAM goods across all suppliers to see whether you are above the 50-tonne threshold.
- If you are above it, apply for authorized CBAM declarant status before importing.
- Ask each supplier for net mass, metal content, material origin and installation data; decide whether to use default values or pursue actual data.
- Keep records of the data and assumptions behind each declaration.
Frequently asked questions
Are sheet metal enclosures subject to CBAM?
If classified under CN 7326 (steel) or 7616 (aluminum), yes. If classified as parts of switchgear under 8538, no. Classification depends on the part’s function and is the importer’s decision.
Are steel springs covered by CBAM?
Heading 7320 (springs of iron or steel) is not listed in Annex I of Regulation (EU) 2023/956. Check the current annex before import, as scope may be extended.
Do small importers have to comply?
Under the 2025 amendment, importers below 50 tonnes of CBAM goods per calendar year are exempt. Check the current rules for how the threshold is calculated.
Can you provide verified CBAM emissions data?
We support data requests with weights, material content, production route and installation information. We do not currently hold verified emissions data, so importers may need to use default values.
Is this page legal advice?
No. It is a summary for buyers. CBAM rules and implementing acts are still evolving; check current rules before import and consult your customs adviser.
Related pages
Import guide
HS codes for sheet metal enclosures and stamped parts
Which HS code fits your sheet metal enclosure or stamped part — 7326, 7616, 8538, 8473 or 9403 — and how the choice changes duty and EU CBAM.
Sheet metal
Custom electrical enclosures
Control boxes, cabinets and automation-equipment housings.
Metal stamping
Custom stamped metal brackets
PCB, connector and mounting brackets stamped from steel, stainless and aluminum strip.
Import guide
Importing metal parts from China to Australia
Duty, GST, ChAFTA certificate of origin, customs and ISPM 15 packaging when importing stamped and sheet metal parts from China to Australia.