CBAM Goods and CN Codes: How to Run a Scope Check That Holds Up

Scope is a list, not a definition

The CBAM Regulation does not define scope through a product description or a sector test. Annex I lists Combined Nomenclature codes, and those codes are the scope. Two consequences follow.

First, scope is not arguable. If a line's code is listed, it is covered; if not, it is not. Second, and more inconveniently, two goods leaving the same production line can be treated differently. There are goods with high carbon intensity that are out of scope, and goods with low carbon intensity that are in.

This is why the assumption "we are a steel company, so all our exports are covered" produces both unnecessary data-collection work and gaps in preparation. The right starting point is a list of actual export lines with their codes, compared against Annex I.

Sector by sector

Cement

The core of scope is CN 2523: cement clinker, white Portland cement, other Portland cements, aluminous cement and other hydraulic cements. Calcined kaolinic clays are also listed. The critical structural point is that clinker is treated as a separate precursor; the embedded emissions of cement are built on the emissions of the clinker it contains.

Iron and steel

The widest and most complex scope, drawing on a substantial part of CN chapters 72 and 73: pig iron and spiegeleisen, part of the ferro-alloys, products of direct reduction of iron ore, semi-finished products, flat-rolled products, bars, rods and profiles, wire, tubes, pipes and hollow profiles, structural components, reservoirs and tanks, stranded wire, and fasteners such as screws and bolts.

Two exclusions matter. Scrap is not in scope, which is material for electric arc furnace production, and only part of the ferro-alloys is listed.

Aluminium

From unwrought aluminium (CN 7601) through bars and profiles, wire, plates and sheets, foil, tubes and certain aluminium articles. Aluminium scrap is out of scope. Alumina and aluminium hydroxide are among the precursors under consideration for future inclusion.

Fertilisers

Nitric acid and sulphonitric acids (CN 2808), ammonia (CN 2814), potassium nitrate, nitrogenous fertilisers (CN 3102) and compound fertilisers containing two or three nutrients (CN 3105). The functional unit is built on nitrate content, and the sector is unique in having its default-value mark-up fixed at 1%.

Electricity and hydrogen

Electricity under CN 2716 and hydrogen under CN 2804 10 00. These two are the exceptions to the 50-tonne de minimis exemption and are in scope regardless of quantity.

Goods commonly mistaken as in scope

• Scrap steel and aluminium. Carries no embedded emissions as an input — although adding pre-consumer scrap as an input emission is under discussion in the anti-circumvention proposals.
• Finished goods containing steel or aluminium. Vehicle parts, machinery and appliances are out of scope today; the downstream extension proposed for 1 January 2028 targets exactly this group.
• Construction materials other than cement. Ready-mixed concrete, brick and ceramics are not covered, although ceramics and glass appear in the review of future scope.
• Stainless and alloyed products. Being within chapter 72 does not automatically mean being in scope.

A scope check in five steps

1. Start from real trade data. Extract CN code, quantity and buyer from twelve months of customs declarations for EU-bound shipments.
2. Match at eight-digit level. Matching at four-digit heading level produces false positives.
3. Identify precursors. The embedded emissions of a covered good include the emissions of its covered precursors — clinker, pig iron, semi-finished steel, ammonia.
4. Assess volume per buyer. The 50-tonne threshold is calculated per importer, so the same product can be in scope for one customer and outside it for another.
5. Re-run periodically. Scope is not static; the 2028 extension and the review due at the end of 2027 may add lines.

Once scope is settled, the next step is building the emissions calculation for the covered lines, which we set out in calculating CBAM embedded emissions. The mechanism as a whole is covered in what is CBAM.

Frequently asked questions

Our code is not listed. Is there anything to do?

Not for current scope. If your product is steel- or aluminium-intensive, check it against the 180-code list proposed for 2028.

Different grades of the same product have different codes. How does that work?

Scope is determined per code. For the emissions calculation, the functional unit is the tonnage produced under the same CN code, so the calculation is also built per code.

We sell a covered good outside the EU. Are we affected?

CBAM applies only to goods released for free circulation in the EU. If your non-EU buyer processes and sells into the EU, however, the data request can still reach you through the chain.

Can a customs broker do the scope check?

Code matching can be done on the customs side. Identifying precursors, system boundaries and functional units requires knowledge of the production process, so the two need to run together.

Sources

• European Commission — CBAM legislation and Annex I
• European Commission — CBAM definitive regime

We work on scope determination and on building the embedded emissions calculation for covered lines, under our CBAM accounting and reporting service. You can contact us with your questions.