Which products are in CBAM scope? CN codes

Whether your product is under CBAM depends on its product code, not on the name of your sector. Of two companies working with steel, one can be in scope and the other out. This article gives the main code groups per sector from Annex I and shows how to run the check. The information was read from the sources on 13 October 2026.

What decides CBAM scope: your local tariff code or the CN code?

The Regulation identifies goods by their Combined Nomenclature (CN) codes, those under Regulation (EEC) No 2658/87 (2023/956 Annex I, point 1). Whatever your own tariff calls the code (GTİP for producers in Türkiye), the EU side uses the CN code and CBAM looks only at that. EU customs authorities report the eight-digit CN code of the goods to the Commission (Art. 25(2)).

So first learn which CN code your buyer uses in its EU import declaration. Scope follows that code.

Origin counts as well. The Regulation applies to goods originating in a third country, and origin follows the rules for non-preferential origin (Art. 2(1), Art. 2(5)).

Which sectors and CN code groups are in CBAM scope?

The table summarises Annex I. A short code (such as 72 or 7318) covers every code under that heading. An eight-digit code means that code only.

Source: 2023/956 Annex I for codes and exceptions; Art. 7(1) and Annex II for the emissions column. Annex II lists iron and steel, aluminium, hydrogen and electricity, and for those goods only direct emissions count.

In plain words, Chapter 73: sheet piling (7301), railway track material (7302), tubes, pipes and hollow profiles (7303 00 to 7306), fittings (7307), structures (7308), tanks, drums and containers (7309 00, 7310, 7311 00), screws, bolts, nuts and washers (7318), other articles of iron or steel (7326).

Aluminium: unwrought (7601), powders and flakes (7603), bars, rods and profiles (7604), wire (7605), plates, sheets and strip (7606), foil (7607), tubes and pipes (7608), fittings (7609 00 00), structures (7610), tanks and containers (7611 00 00, 7612, 7613 00 00), stranded wire and cables (7614), other articles (7616).

How do you check whether your product is in scope?

1. Find the CN code. Ask your buyer for the eight-digit code in its EU import declaration.
2. Look at the first digits. A code starting with 72 is under iron and steel. For 73 or 76, compare the first four digits with the table. For cement, electricity, hydrogen and the fertiliser lines 2808 00 00 and 2834 21 00, all eight digits have to match.
3. Check the exceptions. The first digits may match while the code is excluded: 7204 or 3105 60 00, for example.
4. Check the country of origin. Goods originating in Iceland, Liechtenstein, Norway or Switzerland are outside the Regulation (Art. 2(4), Annex III, point 1). Türkiye is not on that list.
5. Ask your buyer about the threshold. An importer whose in-scope imports in a calendar year do not exceed 50 tonnes of net mass is exempt, except for electricity and hydrogen (Art. 2a(1), 2a(4), Annex VII, point 1).

For the threshold and who carries the obligation, see What is CBAM.

Which products are outside CBAM scope?

A code that is not in Annex I is out of scope. Common cases:

• Scrap: 7204 (ferrous waste and scrap) is expressly excluded in Annex I.
• Some ferro-alloys: ferro-silicon (7202 2), ferro-silico-manganese (7202 30 00), ferro-molybdenum (7202 70 00) and the other 7202 codes in the table.
• Unlisted Chapter 73 headings: 7312 to 7317 and 7319 to 7325 are not in Annex I.
• Unlisted Chapter 76 headings: 7602 and 7615 are not in Annex I.
• Phosphorus and potassium fertiliser: 3105 60 00 is excluded.
• Goods moved or used in the context of military activities (Art. 2(3)).

Source: 2023/956 Annex I. A product containing steel or aluminium but classified under a code that is not in Annex I is not in scope. The code decides, not the material.

What are simple goods, complex goods and precursors?

Once in scope, the next question is how deep the calculation goes. The Regulation defines two kinds of goods:

• Simple goods: goods produced in a process that needs only input materials and fuels with zero embedded emissions (2023/956 Annex IV, point 1(a)).
• Complex goods: all goods other than simple goods (Annex IV, point 1(b)).

The difference comes from precursors. A precursor is an input material that is itself in the Annex I list (2025/2547 Art. 1(7)). If you buy steel sheet and make tubes, the sheet is your precursor and the tube is a complex good. The emissions embedded in the sheet are added to those of the tube (2023/956 Annex IV, point 3).

• Only precursors listed in Annex I count, and precursors from the exempt countries in point 1 of Annex III are not considered (Annex IV, point 3).
• A precursor originating in the Union or in an exempt country is counted with zero embedded emissions (2025/2547 Annex III, point B).
• You may use actual data for your own process and default values for one or more precursors (2025/2547 Art. 15).
• For iron or steel products, plating, cutting, welding and finishing are not monitored; for aluminium products, cutting, welding and finishing (2025/2547 Annex I, points 3.16.2 and 3.18.2). The product stays in scope; only the operations counted change.

The calculation is explained in how embedded emissions are calculated.

What should you do first if you are in scope?

1. Put the CN code and yearly tonnage of every product going to the EU in one list.
2. List the precursors of each product: CN code, supplier, country, quantity. Quantities are determined per production process (2025/2547 Annex II, point E).
3. Ask your precursor supplier for emissions data. Without it, a default value is used for that precursor (2025/2547 Annex II, point E).
4. Agree the method with your buyer: actual emissions or default values (2023/956 Art. 7(2)). Actual emissions need verification (Art. 8(1)).
5. Keep production and energy records for the calendar year in order. The report is built from them: the CBAM report for producers.

Does the scope list change?

Yes. Regulation (EU) 2025/2083 rewrote the kaolinic clay line under cement; the current text leaves non-calcined clays out (2023/956 Annex I). The Commission also has to assess extending the scope to products further down the value chain of the Annex I goods and to other precursors (Art. 30(2)(a), Art. 30(3)). Repeat the check against the current Annex I at least once a year.

The Registamp CBAM module calculates embedded emissions per product from your installation and invoice data and prepares the verifier file and the buyer summary. See the CBAM module page.

This article is general information, not legal advice. For the classification of your product, your EU buyer's customs declaration and the text of the Regulation prevail.

Sources

• Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism; Annex I list of goods (read from the consolidated text of 20 October 2025): eur-lex.europa.eu/eli/reg/2023/956/oj
• Regulation (EU) 2025/2083 amending Regulation 2023/956: eur-lex.europa.eu/eli/reg/2025/2083/oj
• Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions (definition of precursor, system boundaries): eur-lex.europa.eu/eli/reg_impl/2025/2547/oj