CBAM and Melt-and-Pour Evidence: What We Can Document
If you import welded steel structures or machined steel parts into the EU, two things changed in 2026. From 1 January, CBAM entered its definitive period and CN codes 7308, 7311, 7318 and 7326 are inside its scope. From 1 October, you must be able to show where the steel was melted and poured.
Your supplier either hands you that paperwork, or you pay for it — because without verified installation-level emissions data, your import is valued at China's default of 3.167 tCO₂e per tonne of steel, against a blast-furnace benchmark of 1.370.
Which parts are in scope
| CN code | What it covers |
|---|---|
| 7301–7302 | Sheet piling, railway track material |
| 7303–7307 | Tubes, pipes and fittings |
| 7308 | Structures and parts of structures |
| 7311 | Containers for compressed or liquefied gas |
| 7318 | Screws, bolts, nuts and other fasteners |
| 7326 | Other articles of iron or steel |
Why the default value hurts
| Production route | tCO₂e per tonne |
|---|---|
| Scrap electric arc furnace | 0.072 |
| DRI electric arc furnace | 0.481 |
| Blast furnace / basic oxygen furnace | 1.370 |
| China default value | 3.167 |
How the cost phases in
| Year | CBAM factor |
|---|---|
| 2026 | 2.5 % |
| 2027 | 5 % |
| 2028 | 10 % |
| 2029 | 22.5 % |
| 2030 | 48.5 % |
| 2031 | 61 % |
| 2032 | 73.5 % |
| 2033 | 86 % |
| 2034 | 100 % |
The 50-tonne threshold
An EU importer whose total annual imports across Chapters 72 and 73 stay below 50 tonnes in a calendar year is exempt from surrendering certificates. For heavy fabrication that is three or four large assemblies, and the threshold is measured across every CBAM good you import in the year — not per supplier and not per shipment.
What we can give you today
EN 10204 3.1 mill certificates for all supplied steel. Documented melt-and-pour country for every heat, traceable to the mill and the heat number. The production route of the supplying mill. Batch-level traceability from plate to finished part.
What is still in preparation
Verified installation-level emissions data calculated to the EU MRR methodology and checked by an accredited verifier. We are working on it. We would rather tell you exactly where we are than imply we already have it.
If CBAM reporting is on your critical path, tell us your timeline and we will tell you honestly whether we can meet it.
Frequently asked
- Does CBAM apply to machined parts, or only to raw steel?
- It applies to the CN code, not to the amount of processing. A finished machined weldment classified under 7326 is in scope exactly as a hot-rolled plate under 7208 is.
- We import under 50 tonnes a year. Can we ignore this?
- You are exempt from surrendering certificates. You still need melt-and-pour evidence from 1 October 2026 for steel covered by the EU steel measures, and you still want a 3.1 certificate for your own quality file.
- Can you just give us a number for the emissions?
- We can give you the mill's production route and the country of melt and pour, which is what determines the applicable default. We are not going to invent an installation-level figure that has not been verified — an unverified number is worse than no number, because you are the one declaring it.
- What happens if our supplier can't provide this?
- You declare on default values, and from 2028 you pay a 30 % mark-up on top of a country average that is already more than twice the blast-furnace benchmark.
- Do you charge extra for the documentation?
- No. Mill certificates and melt-and-pour records come with the shipment.
Every shipment leaves with the paperwork trail: EN 10204 3.1 mill certificates, documented melt-and-pour origin, welding records, a first-article dimensional report, and the coating and packing record.
Send us the drawing
Acknowledgement within 4 working hours. Full quotation within 48 hours when the drawing package is complete.