EU carbon rules / Industry dossiers / Iron, steel and steel products
NACE C24.1–C24.3 5 duties 11 related regulations
Iron, steel and steel products
The sector with the heaviest carbon cost under CBAM; downstream products are proposed to be covered in 2028.
Reference only: this dossier is public compliance research, not legal advice, and draws no compliance conclusion. Whether a duty applies depends on product classification (CN code), role (importer, EU producer, downstream purchaser), cumulative volumes and Member State application; rely on the legal text and the competent authority.
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Duties
CCarbon: pricing, accounting, reporting, targets EEnvironment: pollution, waste, ecosystems, product attributes
| Duty | Trigger | Evidence needed | Timing | Legal source |
|---|---|---|---|---|
| Carbon Calculate and declare embedded emissions per installation Calculate direct and indirect emissions at installation level, distinguish them by production route and retain verification working papers. | Imports of CBAM-covered steel products (pig iron, crude steel, steel products, etc.) exceeding 50 tonnes per year | Installation-level calculation of direct emissions (including process emissions) and indirect emissions; distinction by production route (blast furnace/EAF); production data and verification report | Recording from 2026; annual declaration | Reg (EU) 2023/956; method per the Implementing Reg (EU) 2023/1773 framework |
| Carbon Obtain the status of authorised CBAM declarant Authorisation must be applied for from the competent authority of the Member State before import, and a cumulative import ledger must be kept. | Importing covered goods in one's own name | Authorisation from the Member State competent authority; import volume ledger (aggregated across steel/aluminium/cement/fertilisers) | 2026-01-01, definitive period | Reg (EU) 2023/956; threshold Reg (EU) 2025/2083 |
| Carbon Purchase and surrender CBAM certificates Purchase certificates corresponding to annual embedded emissions and cancel them in the account by 31 May of the following year. | Embedded emissions corresponding to import volumes in the definitive period | Certificate account and quarterly price records; purchasing starts in 2027-02 | From 2027-02; annual settlement | Reg (EU) 2023/956 |
| Carbon Prepare product carbon footprint ledgers for downstream products in advance Build product-level steel content and emissions data chains for fasteners, steel structures and other products proposed for coverage. | Export of around 180 products proposed for coverage, such as fasteners, springs, steel structures and metal parts for appliances | Product-level steel/aluminium content; supplier embedded emissions data | Proposed for 2028-01 〔under review〕 | COM(2025) 989 final |
| CarbonEnvironment ETS and industrial emissions compliance for EU installations Installations in the EU must monitor and report under the ETS and submit transformation plans under the IED. | Operating blast furnaces/EAFs or other ETS-covered installations in the EU | Monitoring plan, annual emissions report and verification (MRV); IED transformation plan | Ongoing | Directive 2003/87/EC; Directive (EU) 2024/1785 |
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Related regulations
| Regulation | Number | Status | Key date | Applies to |
|---|---|---|---|---|
| CBAM Regulation | Regulation (EU) 2023/956 | In force | 2026-01-01 | Imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen |
| CBAM Simplification Amendment | Regulation (EU) 2025/2083 | In force | 2025-10 | Imports of goods covered by CBAM |
| EU ETS Directive | Directive 2003/87/EC | In force | 2003 | Power, energy-intensive industry, aviation (within the EU/EEA) |
| ETS Transitional Rules for Free Allocation | Delegated Reg (EU) 2019/331 (as amended by 2024/873) | In force | 2019 / 2024 | Industrial installations covered by the EU ETS |
| Industrial Emissions Directive IED 2.0 | Directive (EU) 2024/1785 | In force | 2026-07-01 transposition | Large industrial installations |
| CBAM Downstream Extension | COM(2025) 989 final | In progress | proposed 2028-01 | Steel/aluminium-intensive downstream products (fasteners, machinery parts, household appliances, etc.) |
| Steel and Metals Action Plan | COM(2025) 125 (19.3.2025) | In force | 2025-03-19 | Steel and metals industry |
| Innovation Fund | ETS Directive, Article 10a(8) | In force | continuous | Low-carbon technology projects |
| Mining Waste Directive | Directive 2006/21/EC | In force | 2006 | Extractive industry and mining waste facility operators |
| Product Environmental Footprint (PEF) Method Recommendation | Commission Recommendation (EU) 2021/2279 | In force | 2021 | Companies issuing product environmental footprints and responding to customer data requests |
| Greenhouse Gas Protocol: Corporate Standard (revised edition) | GHG Protocol Corporate Standard | In force | 2004 (revised edition) | Companies establishing corporate GHG inventories and responding to customer accounting requirements |
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