CBAM and Steel Imports: What UK Importers Need to Know

Steel is one of the most carbon-intensive materials in global manufacturing and it represents the largest category of goods affected by CBAM. UK businesses importing steel products from outside the EU need to understand their obligations clearly.

Which steel products are in scope

Not all steel products fall within CBAM scope. The regulation targets goods that are energy-intensive to produce and have significant embedded carbon content. In-scope products include:

•      Crude steel — ingots and primary forms

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

•      Long products — bars, rods, and wire rod

•      Tubes and pipes

•      Certain downstream fabricated products where steel content and manufacturing emissions are significant

The definitive test is whether the goods' CN code appears in Annex I of EU Regulation 2023/956. If you are unsure whether your products are in scope, we can advise.

Embedded emissions: the two production routes

Steel production operates via two primary routes, with very different carbon profiles:

•      Blast furnace / basic oxygen furnace (BF-BOF): The traditional route using coking coal and iron ore. Average embedded emissions are approximately 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.

Importers sourcing EAF-produced steel from mills with low-carbon electricity may have substantially lower CBAM certificate obligations than those sourcing BF-BOF material. Understanding your suppliers' production route is the starting point for managing cost.

The impact of verified emissions data

The EU Commission's default benchmark values for steel are based on conservative average production intensities. Importers who rely on default values pay for more certificates than necessary. Obtaining verified actual emissions data from suppliers — and substituting it for the defaults — is the single most impactful action a steel importer can take to reduce its CBAM liability. In our experience, importers with modern or EAF-based suppliers typically see a reduction of 25–40% in their certificate obligation when switching from defaults to verified data.

What steel importers should do now

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

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

3.    Request verified emissions intensity data from your highest-volume suppliers.

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

5.    Assess your projected annual certificate liability and budget accordingly.

Contact us for a steel-specific CBAM exposure assessment.

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