Iron, steel and steel products · Checklist

CBAM Regulation Regulation (EU) 2023/956 In force Key date:2026-01-01

• Obtain the status of authorised CBAM declarant Registration as an authorised CBAM declarant with the competent authority of a Member State is required before import. Trigger:Importing goods covered by CBAM (steel, aluminium, cement, fertilisers, hydrogen, electricity) · Evidence:Authorised declarant decision, registration details · Timing:Before import
• Submit the annual CBAM declaration Declare the quantity of imported goods, embedded emissions and carbon price paid. Trigger:Each quarter/year in which goods are imported as an authorised declarant · Evidence:CBAM declaration, supplier emissions data, verification documents · Timing:After each quarter; annual declaration by 30 September
• Purchase and surrender CBAM certificates Purchase and surrender CBAM certificates according to embedded emissions; the price is linked to the weekly average EUA price. Trigger:Embedded emissions confirmed in the annual declaration · Evidence:Certificate holding and surrender records, cancellation certificate · Timing:Surrendered after the annual declaration
• Use actual emissions data rather than default values Use of default values is restricted; verified actual emissions data from the production installation must be obtained. Trigger:Importers wishing to reduce certificate costs · Evidence:Verified emissions data provided by the producer, production route description · Timing:From the definitive period starting in 2026

CBAM Simplification Amendment Regulation (EU) 2025/2083 In force Key date:2025-10

• Apply the 50 t de minimis exemption An exemption applies where the total net weight of CBAM goods imported by a single importer in a calendar year does not exceed 50 t. Trigger:Imports of steel, aluminium, cement and fertilisers (aggregated) · Evidence:Import ledger, annual total net weight · Timing:After the 2024/2025 simplification enters into force
• Declare under the simplified rules and use default values The delegated act relaxes certain declaration fields and the use of default values. Trigger:CBAM declarants · Evidence:Simplified declaration records · Timing:After 2025/2083 enters into force

EU ETS Directive Directive 2003/87/EC In force Key date:2003

• Obtain a greenhouse gas emissions permit Before operating an installation covered by the ETS, obtain a GHG emissions permit from the competent authority of the Member State and draw up a monitoring plan. Trigger:Operating an activity listed in Annex I to the ETS Directive (power generation, energy-intensive industry, aviation, etc.) · Evidence:GHG emissions permit, monitoring plan · Timing:Obtained before operation; valid on a continuing basis
• Monitor and report annual emissions Calculate in accordance with the MRR and submit an annual emissions report after verification by an accredited verifier. Trigger:Each operating year in which an emissions permit is held · Evidence:Monitoring methodology document, verified annual emissions report (AVR) · Timing:Submitted by 31 March of the following year
• Surrender a sufficient number of allowances Surrender EUAs equal to annual emissions; in case of a shortfall, a penalty of €100/t applies and the allowances must still be surrendered. Trigger:Annual emissions verified and confirmed · Evidence:Allowance account surrender records, cancellation certificate · Timing:By 30 September of the following year

ETS Transitional Rules for Free Allocation Delegated Reg (EU) 2019/331 (as amended by 2024/873) In force Key date:2019 / 2024

• Submit activity level data and an allocation application Apply for free allocation under the benchmark method and submit a verified baseline-year activity level report (HAR). Trigger:Installations eligible for free allocation · Evidence:Verified activity level report, monitoring methodology documents · Timing:Each year of the allocation period (free allocation until 2030)
• Comply with the monitoring and reporting requirements as amended by 2024/873 The free allocation rules are simplified, but product benchmarks must be monitored under the latest methodology. Trigger:Installations receiving free allocation · Evidence:Updated monitoring methodology documents · Timing:After 2024/873 enters into force

Industrial Emissions Directive IED 2.0 Directive (EU) 2024/1785 In force Key date:2026-07-01 transposition

• Obtain an IED integrated permit and comply with BAT Operate in accordance with best available techniques (BAT/BREF) and apply an environmental management system. Trigger:Industrial activities listed in Annex I to the IED · Evidence:IED permit, BAT compliance assessment, environmental management system · Timing:After transposition of 2024/1785
• Submit a transformation plan The new IED requires high-emission installations to provide a decarbonisation transformation plan. Trigger:Energy-intensive installations subject to the IED · Evidence:Decarbonisation transformation plan · Timing:After transposition of 2024/1785

CBAM Downstream Extension COM(2025) 989 final In progress Key date:proposed 2028-01

• Prepare supply chain emissions data for downstream products Around 180 steel- and aluminium-intensive downstream products are planned for inclusion; upstream emissions data must be obtained in advance. Trigger:Exporting fasteners, steel wire, springs, household appliances, machinery parts, etc. to the EU · Evidence:Supplier carbon footprint data, bill of materials (BOM) · Timing:Planned from 2028 [under review]

Steel and Metals Action Plan COM(2025) 125 (19.3.2025) In force Key date:2025-03-19

• Monitor trade protection and CBAM expansion for steel and metals The action plan includes import monitoring, protection of primary steel and downstream expansion of CBAM. Trigger:Steel and metals producers/exporters · Evidence:Policy tracking, impact assessment · Timing:From 2025

Innovation Fund ETS Directive, Article 10a(8) In force Key date:continuous

• Apply for Innovation Fund support Funding is provided for breakthrough low-carbon technologies through calls for proposals. Trigger:Companies with emission reduction technology projects · Evidence:Project application, emission reduction and financing plan · Timing:According to call cycles

Mining Waste Directive Directive 2006/21/EC In force Key date:2006

• Prepare an extractive waste management plan Prevent or minimise waste generation and ensure its safe disposal. Trigger:Generating or managing extractive waste · Evidence:Waste management plan, waste classification and ledger · Timing:Before operation and on a continuing basis
• Apply major accident prevention measures at Category A facilities Waste facilities classified as Category A by the competent authority must establish a major accident prevention policy and emergency procedures. Trigger:Facility classified as Category A · Evidence:Major accident prevention policy, emergency plan and drill records · Timing:Before operation

Product Environmental Footprint (PEF) Method Recommendation Commission Recommendation (EU) 2021/2279 In force Key date:2021

• Use PEF / OEF methods to measure and communicate environmental performance When voluntarily measuring or communicating life-cycle environmental performance, environmental footprint methods should be used. Trigger:Voluntary measurement or communication of life-cycle environmental performance · Evidence:PEF / OEF study report · Timing:Ongoing
• Use category rules where a PEFCR exists Where a PEFCR exists for a product category, the environmental footprint must be calculated according to the category rules. Trigger:A PEFCR exists for the product category · Evidence:PEFCR applicability statement and calculation documents · Timing:Ongoing
• Complete verification before disclosure to third parties PEF / OEF studies disclosed to third parties must be verified in accordance with the methodological requirements. Trigger:Disclosing a PEF / OEF study to third parties · Evidence:Verification report · Timing:Before disclosure

Greenhouse Gas Protocol: Corporate Standard (revised edition) GHG Protocol Corporate Standard In force Key date:2004 (revised edition)

• Determine organisational boundaries and choose a consolidation approach Define the operational scope covered by the inventory using the equity share or control approach. Trigger:Preparing a corporate GHG inventory · Evidence:Boundary document, consolidation approach description · Timing:In the first year and on boundary changes
• Define and account for Scope 1 / 2 / 3 emissions Distinguish direct emissions, indirect emissions from purchased electricity and other value chain indirect emissions. Trigger:Establishing and maintaining a GHG inventory · Evidence:Emissions source inventory, scope classification and emission factors · Timing:Ongoing
• Follow the transparency principle and retain an audit trail Record processes, assumptions and limitations so that a third party can reproduce the results from the same source data. Trigger:Reporting GHG data · Evidence:Assumptions and limitations statement, audit trail documentation · Timing:Ongoing