CBAM and Your Chinese Fabricator: What Data You Actually Need

Most of the CBAM conversation over the past two years has been about steel mills. If you buy finished parts rather than raw steel, it was easy to assume the problem belonged to somebody upstream.

It doesn't. Since 1 January 2026 the Carbon Border Adjustment Mechanism has been in its definitive period, and the scope is written in CN codes, not in how much work has been done to the metal. A welded assembly that has been cut, formed, welded, stress-relieved, machined and painted is still classified under Chapter 73 — and several of the most common Chapter 73 codes are inside CBAM.

If you import fabricated steel parts into the EU, this is now your problem, and the paperwork that solves it has to come from your supplier.

Which parts are in scope

CBAM covers Chapter 72 and parts of Chapter 73. The Chapter 73 codes matter most to anyone buying fabricated parts:

Most weldments and machined steel parts land in 7308 or 7326. That last one is a catch-all, and it catches a great deal.

The first thing to do is not to read another CBAM explainer. It is to pull your last twelve months of import declarations and look at the commodity codes you actually used.

The 50-tonne threshold, and why it protects fewer people than they think

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. It sounds generous.

For anyone buying heavy fabricated parts, 50 tonnes 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. A buyer who takes two crushers' worth of wear liners from China, some fasteners from India and a few pressure vessels from Turkey adds all of it together.

What the default value actually costs

Here is where the money is.

If your supplier cannot give you verified installation-level emissions data, your declaration falls back to a default value set by country and product. For steel from China, that default is 3.167 tonnes of CO₂e per tonne of steel.

Set that next to the benchmarks for the actual production routes:

The default is more than twice the blast-furnace benchmark. That is not an accident of measurement. Default values under the CBAM implementing regulation carry a deliberate mark-up above the country-sector average — 10 % in 2026, 20 % in 2027, and 30 % from 2028 onwards. The mechanism is designed to make collecting real data worth the effort.

So a buyer who accepts "we don't have that data" from a supplier is not choosing between two similar numbers. They are choosing to declare roughly two and a half times the emissions the steel probably actually carried, and then to pay a mark-up on top.

Why the bill is small this year and large by 2030

The reason many importers have not felt this yet is the phase-in. CBAM obligations rise as free allocation under the EU Emissions Trading System is withdrawn:

In 2026 you surrender certificates against 2.5 % of the embedded emissions. With EU allowances trading in the region of €74–82 per tonne through 2026, the cost on a modest order is genuinely small.

By 2030 the factor is nearly twenty times higher. The supplier you qualify this year is very likely the supplier you are still buying from then, and the difference between one that can document its steel and one that cannot compounds every year in between.

The first declaration and certificate surrender covering 2026 imports falls due on 30 September 2027. That is the date by which your records need to exist, not the date to start collecting them.

The five documents to ask your supplier for

None of this requires your supplier to be sophisticated. It requires them to keep records and hand them over. Ask for these, by name:

1. The mill test certificate, EN 10204 3.1, for every heat. This is standard practice and any credible fabricator issues it without being asked. If a supplier hesitates here, stop.

2. The country where the steel was melted and poured. Not the country of the fabricator, not the port of loading — the country where the liquid steel was originally cast. From 1 October 2026 you need to be able to evidence this for steel covered by the EU steel measures anyway, so you will be asking for it regardless of CBAM.

3. The production route of the supplying mill. Blast furnace / basic oxygen furnace, direct reduced iron with electric arc furnace, or scrap electric arc furnace. This single line determines which benchmark your steel sits near, and it is information the mill knows without doing any new work.

4. The installation. The specific plant, not just the company. CBAM data is reported at installation level, and a large steel group may operate installations with materially different footprints.

5. Verified emissions data, where it exists. Actual emissions calculated to the EU Monitoring and Reporting Regulation methodology and checked by an accredited verifier. This is the one that costs the supplier money and takes time. It is entirely reasonable for a supplier not to have it yet in 2026. It is not reasonable for them to imply that they do.

How to read the answers you get

You will get three kinds of response.

"We don't know what you're talking about." That is at least honest, and it is where a lot of the market still is. Whether it is disqualifying depends on how much you buy and how fast you need the data.

"Yes, we have full CBAM certification." Be careful with this one. There is no such thing as CBAM certification for a supplier. There are CBAM certificates, which are the instruments an EU importer buys and surrenders — the supplier does not hold them. A supplier can hold *verified emissions data*. If they describe it any other way, they are repeating a phrase rather than describing a document. Ask to see the verifier's report.

"Here is the mill, the installation, the route and the melt-and-pour country. Verified emissions data is in preparation." This is the good answer in 2026. It means the supplier understands the chain, has the traceability in place, and is not overstating where they are.

Where we are

We supply EN 10204 3.1 mill certificates as standard, document the melt-and-pour country for every heat against the job number, and can state the production route of the supplying mill. Traceability runs from plate to finished part.

Verified installation-level emissions data to the MRR methodology, checked by an accredited verifier, is in preparation. We would rather tell you exactly where we are than let you assume more.

If CBAM reporting is on your critical path, tell us your timeline and we will tell you honestly whether we can meet it.

FAQ

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 a supplier just give us an emissions number? They can give you a number. Whether you should declare it depends on whether it was calculated to the EU methodology and verified. An unverified number is worse than no number, because you are the one declaring it.

What is the difference between the default value and the benchmark? The benchmark describes what a given production route typically emits. The default value is what the EU applies to your import when nobody has supplied verified actual data, and it is set deliberately above the country-sector average.

Is CBAM going to cover more products? The Commission published a proposal in December 2025 to extend the scope from 1 January 2028 to a large group of downstream steel- and aluminium-intensive goods. If your product is not in scope today, check again before you build a long-term supply plan around that assumption.

Sources Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025 (CBAM default values), as corrected by Implementing Regulation (EU) 2026/1740; Commission Implementing Regulation (EU) 2025/2547 (accreditation of verifiers); European Commission CBAM legislation and guidance; EU ETS allowance prices, 2026.