If you import goods into the EU, you’ve likely heard of the Carbon Border Adjustment Mechanism (CBAM). It’s the EU’s policy for putting a carbon cost on certain imported products, making sure foreign producers face similar climate costs to EU manufacturers.

The goal is to stop carbon leakage: when production shifts abroad to avoid EU emissions rules, and keep competition fair. 

As of 2025, importers must report the emissions tied to covered goods. Starting in 2026, they’ll also need to buy certificates based on those emissions.

This guide breaks down which sectors and products are currently covered, with clear examples to help you assess if your imports are in scope, and what to do next.

CBAM scope: Which sectors and products are covered?

The EU’s priority is to target sectors with the highest risk of carbon leakage. These are industries that generate huge amounts of emissions and face tough international competition. 

For now, CBAM zooms in on six main sectors:

• Iron and steel
• Cement
• Aluminium
• Fertilisers
• Electricity
• Hydrogen

It also includes some precursor materials and processed products linked to these sectors.

The official CBAM rules use Combined Nomenclature (CN) codes to define exactly which products fall under each category. While CN codes are essential for reporting, at a high level, the scope is based on the type of material or product and its typical emissions intensity.

If you import goods from any of these sectors, even if only occasionally, it’s important to assess whether they meet the CBAM criteria for reporting.

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Sector breakdown: What’s in scope today?

As we’ve learnt, CBAM currently covers six sectors that are responsible for high levels of industrial emissions. Here’s what’s included in each sector in more detail:

Iron & Steel

This is one of the broadest categories. Covered products include agglomerated ores, pig iron, crude steel, and a wide range of finished and semi-finished products (bars, rods, rails, wires, tubes, plates, tanks, drums, bolts, nuts, etc.).

Most ferro-alloys are excluded except ferro-manganese, ferro-chromium, and ferro-nickel. Scrap and remelted steel are also excluded.

Emissions profile: Significant emissions from both energy use and chemical reduction processes.

Find everything you need to know about importing iron and steel here.

Cement

CBAM covers a range of cement products, including cement clinkers, white Portland cement, other Portland cements, aluminous cements, hydraulic cements, and some kaolinitic clays.

Emissions profile: Cement production is highly carbon-intensive due to both fuel combustion and the chemical process of calcination.

Find everything you need to know about importing cement here.

Aluminium

Unwrought aluminium, powders, flakes, and a variety of processed aluminium products are included (rods, wires, plates, sheets, structures, containers, etc.).

Certain alloys outside the listed product codes may be exempt.

Emissions profile: High indirect emissions from electricity use, especially in primary aluminium production.

Find everything you need to know about importing aluminium here.

Fertilisers

CBAM applies to several fertilisers and raw materials, including nitric acid, sulphuric acid, ammonia (both anhydrous and aqueous), nitrates of potassium, and mixed fertilisers containing nitrogen, phosphorus, and potassium.

Emissions profile: Mainly from the chemical processes and high energy use in manufacturing.

Find everything you need to know about importing fertilisers here.

Electricity

Electricity imported from non-EU countries. Emissions are calculated based on the carbon intensity of production in the exporting country.

Emissions profile: Varies widely depending on energy sources (coal, gas, renewables, etc.).

Find everything you need to know about importing electricity here.

Hydrogen

All hydrogen imports are included.

Emissions profile: Hydrogen’s emissions vary widely depending on production method, ranging from high (grey) to near-zero (green).

Find everything you need to know about importing hydrogen here.

Keep in mind: This list is set to expand after 2025. 

The European Commission is considering adding other high-emission goods like certain chemicals, polymers, and more products involving indirect emissions.

How to check if your imports are in scope

If you import goods into the EU, checking whether they fall under CBAM is essential for planning your reporting and future certificate costs. 

Here’s how to confirm if your imports are covered:

1. Map your goods to CN codes

Start by identifying the CN codes for your imported products. These are the official product classification codes used in EU customs. CBAM applies to specific CN codes listed in Annex I of the regulation.

2. Check the country of origin and production method

Goods imported from EU Emissions Trading Scheme-linked countries (like Norway, Iceland, Liechtenstein, and Switzerland) are exempt. For other countries, you’ll also need to assess the production method, especially for emissions-heavy processes.

3. Cross-reference with CBAM scope documentation

Compare your product’s CN code and characteristics against the official CBAM guidance and scope documentation. The EU also offers a self-assessment tool to help importers determine if their goods are in scope. Keep in mind that product scope may expand in the coming years, so ongoing checks are essential.

4. Coordinate across teams

Mapping CBAM exposure isn’t just a compliance task. Sustainability, procurement, and trade compliance teams need to work together to verify supplier emissions data, CN codes, and production details.

Are there any exemptions?

CBAM includes a few exemptions during the transitional phase (ending 31 December 2025) to reduce admin for smaller importers and specific trade flows:

• Low-value consignments under €150 are exempt from reporting.
• Returned goods (re-imported without modification) are excluded.
• Outward processing goods brought back under customs procedure are not covered.

The European Commission has proposed a de minimis threshold under the Omnibus Simplification package to exempt importers of under 50 tonnes per year of iron and steel, aluminium, cement, or fertilisers. This proposal hasn’t been approved yet, so current CBAM rules still apply.

Real-world examples: What CBAM challenges might look like

Every importer’s CBAM journey will look a little different depending on the products they handle and the readiness of their suppliers. Here are a few practical scenarios mid-market enterprises might face as they prepare for stricter requirements.

Example 1: A mid-sized aluminium importer moving away from default values

Say you’re an aluminium importer that used default values for emissions reporting in 2024. In 2025, you now need verified emissions data from each supplier. You engage procurement to request data aligned with the EU methodology, but some overseas producers can’t provide it, forcing you to reassess suppliers or arrange third-party verification.

Example 2: A steel component buyer struggling with supplier data

Or imagine you’re sourcing steel components from multiple smaller suppliers. As CBAM reporting deadlines approach, you find inconsistent emissions data across the supply chain. You decide to centralize data collection in an ESG platform to standardize methods and catch gaps early.

Example 3: A fertiliser distributor preparing for 2026 payments

If you distribute fertilisers, some suppliers may still be unfamiliar with CBAM rules. You proactively provide them with EU calculation templates and explain that indirect (electricity-related) emissions must also be reported, not just direct emissions.

The key is acting now to close data gaps, align with EU rules, and avoid last-minute compliance risks in 2026.

What happens when the scope expands?

CBAM isn’t standing still. At the end of 2025, the European Commission will conduct a formal review of the mechanism. One key focus: expanding the scope to include more carbon-intensive products like polymers, organic chemicals, and glass.

These changes aren’t expected overnight, but they are expected. The next wave of sectors could be added by 2027 or 2028, giving companies a narrow window to prepare.

If your business imports goods that could be added next, now’s the time to start building supplier engagement and mapping emissions. Getting ahead of the curve now will make future compliance far less painful.

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Next steps for importers

2025 is the final year to get your CBAM compliance foundations in place. Start by mapping all imported goods against the current CBAM scope and confirming their CN codes. Work with procurement and sustainability teams to request emissions data from suppliers, early engagement is key.

Make sure the data you collect follows the EU’s official methodology. This will prevent costly surprises when certificate purchasing begins in 2026.

Coolset helps mid-market importers simplify emissions data collection, stay compliant with CBAM rules, and plan ahead for certificate costs. Talk to us today to get started.