The EU Carbon Border Adjustment Mechanism (CBAM) applies to a specific set of carbon-intensive goods imported into the EU. Understanding which goods fall under CBAM is the first step for any importer assessing their compliance obligations. This guide provides a sector-by-sector breakdown of what’s covered, what’s included at the product level, and what’s excluded.

How CBAM defines covered goods

CBAM applies to goods listed in Annex I of the CBAM Regulation, organized by Combined Nomenclature (CN) codes. Coverage is based on the CN code of the product being imported, not the end use or the material content. If your imported product has a CN code listed in Annex I, it is a CBAM good.

The definitive phase of CBAM (from January 2026) maintained the same six-sector scope as the transitional phase. For the latest updates on the scope and calculation requirements, see our full guide to CBAM reporting requirements.

The six CBAM sectors

1. Cement

CBAM covers clinker, cement, and related products (CN 2507, 2523). This is one of the highest-emission sectors globally, with cement production accounting for approximately 8% of global CO2 emissions. Embedded emissions include process emissions from calcination as well as combustion emissions.

2. Iron and Steel

Iron and steel is the broadest CBAM sector, covering primary iron, steel, pig iron, sponge iron, flat and long steel products, and many downstream steel products including tubes, pipes, and structural profiles. The full list of CN codes runs to several dozen entries.

Embedded emissions for steel include blast furnace and electric arc furnace emissions, as well as emissions from associated production processes like sintering and coking.

3. Aluminium

CBAM covers unwrought aluminium, aluminium alloys, and a range of semi-fabricated products including foil, plates, sheets, and extruded profiles. Both primary (smelted) and recycled (secondary) aluminium are covered, though primary aluminium carries significantly higher embedded emissions.

4. Fertilisers

The fertiliser sector coverage includes ammonia (both anhydrous and in solution), nitric acid, ammonium nitrate, and mixed fertilisers containing nitrogen. Embedded emissions for nitrogenous fertilisers are closely tied to the Haber-Bosch process for ammonia synthesis, which is highly energy-intensive.

5. Electricity

CBAM covers direct imports of electricity into the EU. This is a technically distinct category — electricity is measured in MWh rather than tonnes, and embedded emissions represent the generation mix of the country of origin. The electricity CBAM is primarily relevant for member states with cross-border interconnectors to non-EU countries.

6. Hydrogen

Hydrogen was added to the CBAM scope in the final regulation. Both uncompressed and compressed hydrogen are covered. Embedded emissions vary enormously by production method: electrolysis (especially green hydrogen) produces far lower emissions than steam methane reforming (grey or blue hydrogen).

How to check if your goods are covered

To determine if your imports fall under CBAM:

1. Identify the CN codes of your imported goods (from customs documentation or tariff classification)
2. Check those CN codes against the Annex I list in the CBAM Regulation
3. If the CN code is listed, the good is in scope for CBAM reporting and certificate obligations

For guidance on what to do next once you’ve confirmed your goods are in scope, see our guide to CBAM reporting requirements.

How Coolset supports CBAM compliance

Coolset’s CBAM module helps importers manage the full compliance workflow: mapping in-scope goods, collecting embedded emissions data from suppliers, and preparing CBAM declarations. Book a demo to see how it works.