CBAM and Steel Imports: What UK Importers Need to Know

Steelis one of the most carbon-intensive materials in global manufacturing and itrepresents the largest category of goods affected by CBAM. UK businessesimporting steel products from outside the EU need to understand theirobligations clearly.

Which steel products are in scope

Notall steel products fall within CBAM scope. The regulation targets goods thatare energy-intensive to produce and have significant embedded carbon content.In-scope products include:

•      Crude steel — ingots andprimary forms

•      Flat-rolled products —hot-rolled coil, cold-rolled coil, coated sheet

•      Long products — bars, rods,and wire rod

•      Tubes and pipes

•      Certain downstreamfabricated products where steel content and manufacturing emissions aresignificant

Thedefinitive test is whether the goods' CN code appears in Annex I of EURegulation 2023/956. If you are unsure whether your products are in scope, wecan advise.

Embedded emissions: the two production routes

Steelproduction operates via two primary routes, with very different carbonprofiles:

•      Blast furnace / basicoxygen furnace (BF-BOF): The traditionalroute using coking coal and iron ore. Average embedded emissions areapproximately 2.0–2.3 tonnes of CO2 per tonne of crude steel.

•      Electric arc furnace(EAF): Uses scrap steel and electricity.Average embedded emissions are approximately 0.4–0.6 tonnes of CO2 per tonne —though this varies significantly depending on the electricity source.

Importerssourcing EAF-produced steel from mills with low-carbon electricity may havesubstantially lower CBAM certificate obligations than those sourcing BF-BOFmaterial. Understanding your suppliers' production route is the starting pointfor managing cost.

The impact of verified emissions data

TheEU Commission's default benchmark values for steel are based on conservativeaverage production intensities. Importers who rely on default values pay formore certificates than necessary. Obtaining verified actual emissions data fromsuppliers — and substituting it for the defaults — is the single most impactfulaction a steel importer can take to reduce its CBAM liability. In ourexperience, importers with modern or EAF-based suppliers typically see areduction of 25–40% in their certificate obligation when switching fromdefaults to verified data.

What steel importers should do now

1.    Identify all steel CN codesin your import portfolio and confirm which are in CBAM scope.

2.    Map your supplier base byproduction route — BF-BOF vs EAF — and by country.

3.    Request verified emissionsintensity data from your highest-volume suppliers.

4.    Register as an AuthorisedDeclarant if you have not already done so.

5.    Assess your projectedannual certificate liability and budget accordingly.

Contactus for a steel-specific CBAM exposure assessment.

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