CBAM CN Code Reference: 2026 List with Sector Mapping
2026-04-20 · 14 min read
Wrong CN code equals wrong sector benchmark equals wrong certificate cost. Sometimes wrong by a factor of three. This is the cheapest mistake to make in a CBAM declaration and the most expensive one to correct after the fact, because reopening a 2026 quarterly declaration triggers an Article 22 adjustment and interest under Article 26(5) of Regulation (EU) 2023/956.
This post is a working reference for the Annex I CN code list as it applies for the 2026 reporting year, grouped by sector, with the default embedded emissions values from Implementing Regulation (EU) 2023/1773 and the 2025 amending acts. It’s long on purpose — put it in your bookmarks.
The six sectors
Annex I of the CBAM Regulation defines six goods sectors. They are not equal in complexity, nor in the volume of trade they catch:
- Cement — relatively narrow, high emissions intensity.
- Iron and steel — wide. Most CN chapters 72, 73 and parts of 82 and 83.
- Aluminium — chapter 76, unwrought and wrought.
- Fertilisers — selected codes in chapters 28 and 31.
- Electricity — a single code with very specific attribution rules.
- Hydrogen — one code, added late in the process.
The full list sits in Annex I. Since 1 January 2025, Implementing Regulation (EU) 2025/… added several processed-steel codes that had escaped the original list (explained below in the “late additions” section).
Cement
CN codes in scope (Annex I table 1):
- 2523 10 00 — Cement clinkers
- 2523 21 00 — White Portland cement, whether or not artificially coloured
- 2523 29 00 — Other Portland cement
- 2523 30 00 — Aluminous cement
- 2523 90 00 — Other hydraulic cements
- 2507 00 80 — Other kaolinic clays (calcined) — added as a precursor
- 2523 90 00 — Other hydraulic cements
Default embedded emissions (from IR 2023/1773 Annex IV as amended for 2026):
| CN code | Good | Default SEE (t CO2 / t good) |
|---|---|---|
| 2523 10 00 | Cement clinker | 0.82 |
| 2523 29 00 | Portland cement (other) | 0.58 |
| 2523 30 00 | Aluminous cement | 0.48 |
The cement sector’s default values are derived from the 10% worst-performing installations in the originating third country, or the EU-ETS benchmark if no third-country data is available. Since 1 August 2026 (first real payment quarter), the Commission publishes the applicable default values quarterly at taxation-customs.ec.europa.eu/cbam.
Iron and steel
This is the widest sector. The full Annex I list for iron and steel runs to approximately 80 CN codes. Key ones:
- 7201 — Pig iron and spiegeleisen, in pigs, blocks or other primary forms
- 7202 — Ferro-alloys (specified subheadings)
- 7203 — Ferrous products obtained by direct reduction of iron ore (DRI) and other spongy ferrous products
- 7206, 7207 — Iron and non-alloy steel, ingots and semi-finished
- 7208 — Flat-rolled products of iron or non-alloy steel, hot-rolled, not clad, width ≥ 600 mm
- 7209 — Flat-rolled products, cold-rolled, width ≥ 600 mm
- 7210 — Flat-rolled products, clad, plated or coated
- 7213, 7214, 7215, 7216 — Bars, rods, angles, shapes, sections
- 7217 — Wire of iron or non-alloy steel
- 7218 through 7229 — Stainless and other alloy steels, same structure
- 7301, 7302 — Sheet piling, railway track construction material
- 7303, 7304, 7305, 7306 — Tubes, pipes and hollow profiles
- 7307 — Tube or pipe fittings
- 7308 — Structures of iron or steel
- 7310 — Tanks, casks, drums
- 7311 — Containers for compressed or liquefied gas
- 7318 — Screws, bolts, nuts, washers (added 2025)
- 7326 — Other articles of iron or steel
Default SEE values (selected, IR 2023/1773 Annex IV):
| CN code | Good | Default SEE (t CO2 / t good) |
|---|---|---|
| 7203 | DRI | 1.13 |
| 7206/7207 | Crude steel | 2.03 |
| 7208 10 00 | Hot-rolled coil | 2.155 |
| 7208/7209 (other) | Hot/cold rolled sheet | 2.155 |
| 7216 | Sections | 2.10 |
| 7304 | Seamless tubes | 2.35 |
| 7318 | Fasteners | 3.85 |
The precursor rules matter a lot here. A hot-rolled coil (CN 7208) inherits emissions from its crude steel precursor (CN 7206/7207) plus the rolling step. If your supplier submits a Communication (the data exchange under IR 2023/1773 Annex IV section 3), the figures you use are the actual ones. If they don’t, you fall back to default values — which are almost always worse for you.
Aluminium
CN codes in scope:
- 7601 — Unwrought aluminium (7601 10 for unalloyed, 7601 20 for alloys)
- 7603 — Aluminium powders and flakes
- 7604 — Aluminium bars, rods and profiles
- 7605 — Aluminium wire
- 7606 — Aluminium plates, sheets and strip > 0.2 mm
- 7607 — Aluminium foil ≤ 0.2 mm
- 7608 — Aluminium tubes and pipes
- 7609 — Aluminium tube or pipe fittings
- 7610 — Aluminium structures
- 7611 — Aluminium reservoirs, tanks, vats
- 7612 — Aluminium casks, drums
- 7613 — Aluminium containers for compressed or liquefied gas
- 7614 — Stranded wire, cables
- 7616 — Other articles of aluminium
Default SEE values are split between direct emissions (from the smelter process) and indirect emissions (from electricity used in electrolysis, which is the dominant share for primary aluminium).
| CN code | Good | Direct SEE | Indirect SEE |
|---|---|---|---|
| 7601 10 | Unwrought unalloyed Al (primary) | 1.60 | 10.50 |
| 7601 20 | Unwrought Al alloys | 1.60 | 10.50 |
| 7604/7605 | Bars, wire | 1.85 | 10.80 |
| 7606 | Plates, sheets | 1.85 | 10.80 |
The indirect column is the one that surprises first-time declarants. Primary aluminium is about 85–90% electricity-cost by emissions. Article 7(7) of the CBAM Regulation and IR 2023/1773 Article 7 spell out how indirect emissions are attributed — including the country-specific grid emission factor or the EU-ETS product benchmark.
Fertilisers
CN codes in scope:
- 2808 00 00 — Nitric acid; sulphonitric acids
- 2814 — Ammonia, anhydrous or in aqueous solution
- 2834 21 00 — Nitrates of potassium
- 3102 — Mineral or chemical fertilisers, nitrogenous (multiple subheadings)
- 3105 — Mineral or chemical fertilisers containing N, P, K (multiple subheadings)
Default SEE values:
| CN code | Good | Default SEE (t CO2 / t good) |
|---|---|---|
| 2814 | Ammonia | 2.36 |
| 2808 00 00 | Nitric acid | 1.32 |
| 3102 10 | Urea | 1.65 |
| 3105 20 | Mineral fertilisers with N, P, K | 1.25 |
Nitrous oxide (N₂O) emissions from nitric acid production are included and are a big part of why 2808 has a high SEE relative to the simple chemistry. The global warming potential used is the IPCC AR5 value (265 for N₂O) — confirmed in IR 2023/1773 Article 7(3) and Annex III.
Electricity
Single code: 2716 00 00 — Electrical energy.
Electricity is the weirdest sector. Attribution under Article 7(4)–(6) CBAM Regulation and IR 2023/1773 Annex III section 6 uses one of three approaches depending on whether the imported electricity can be linked to a specific installation: (1) actual emissions where verifiable, (2) weighted average grid emissions factor of the exporting country, or (3) a CO2 emission factor in the default range.
Default emission factor (for third countries where verified data is not available): 0.70 t CO2 / MWh for the 2026 reporting year, subject to quarterly update by the Commission.
Hydrogen
Single code: 2804 10 00 — Hydrogen.
Default SEE: 11.33 t CO2 / t H2 (grey hydrogen benchmark, IR 2023/1773 Annex IV as amended).
Hydrogen joined the list in the 2024 review. For low-carbon hydrogen imports, the supplier’s Communication is critical — the default value assumes steam methane reforming without CCS, which is basically the worst-case figure.
The late additions (2025 amending acts)
The Commission adopted two amending implementing regulations in 2025 that added processed-steel and processed-aluminium products to Annex I. Selected additions relevant to most importers:
- 7318 12 to 7318 19 — Screws, bolts, nuts, other threaded articles (steel fasteners)
- 7323 — Table, kitchen or other household articles, of iron or steel
- 7324 — Sanitary ware and parts thereof, of iron or steel
- 7325 — Other cast articles of iron or steel
- 7616 99 — Other articles of aluminium (catches a wide range of finished aluminium goods)
These additions took effect from 1 January 2026 for the first annual declaration cycle. If your procurement team was using a 2024-vintage CN lookup, check whether any screws, household goods or finished aluminium articles you import have quietly come into scope. The bill for a year of missed declarations adds up.
Using the AutoCBAM CN check
The lookup tool at autocbam.com/cn-check takes a CN code and returns: (a) whether it’s in Annex I, (b) which sector, (c) the default SEE for the current quarter, (d) the precursor chain, and (e) whether it was part of the 2025 additions. No login required.
For live declarations you’ll still need to submit via the EU CBAM Registry (explained in our Authorised CBAM Declarant guide). But for the “should I care about this import?” question, the CN check is fast.
Worked example: 500 tonnes of hot-rolled coil from Turkey
Bank Przykładowy — just kidding, that’s the Governancer example. Let’s use StalHandel sp. z o.o., a Polish steel trader that imports construction-grade hot-rolled coil from Türk Çelik A.Ş., a Turkish mill near İzmir.
- CN code. 7208 10 00 (hot-rolled coil, non-alloy, >600 mm wide).
- Sector. Iron and steel.
- Tonnage. 500 t in Q2 2026.
- Emissions data from supplier. None received — Türk Çelik hasn’t issued a Communication under IR 2023/1773.
- Default SEE. 2.155 t CO2/t for direct emissions. No indirect emissions attribution for steel finishing (unlike aluminium).
- Total embedded emissions. 500 × 2.155 = 1,077.5 t CO2.
- CBAM certificate price (Q2 2026 average EU ETS auction). Let’s say €85/t CO2 (real-world prices in 2026 have been in the €75–€95 range; use the actual published quarterly average in your declaration).
- Certificate cost. 1,077.5 × €85 = €91,587.50.
- Origin-country carbon adjustment. Turkey’s ETS is in pilot as of 2026 and no effective carbon price applies to steel in İzmir yet. Adjustment: zero.
- Free allowance factor for 2026. Article 36(2)(b) sets the CBAM adjustment factor at 97.5% for 2026 (because EU ETS free allocation for the sector is phased out at 2.5% in 2026). So the declarant actually owes 2.5% × €91,587.50 = €2,289.69 for Q2 2026 alone on this import.
That 2.5% jumps to 48.5% in 2030 and 100% in 2034 per the Article 36 schedule. The same 500 t in Q2 2034: €91,587.50 at full price. Plan for that.
If StalHandel could get a Communication from Türk Çelik showing actual SEE of, say, 1.8 t/t (efficient BF-BOF route with some CCS), the math becomes:
500 × 1.8 × €85 × 2.5% = €1,912.50 for Q2 2026.
Worth the email to the supplier? Yes. Over the 2026–2034 ramp, that data quality saves five-figure-plus on this single supply line.
What AutoCBAM does with this
We maintain the CN-to-sector mapping and pull the quarterly default values from the Commission publication feed. The declaration workflow pre-fills sector, default SEE and expected certificate count from a CN code lookup, so you don’t hand-key the defaults. For suppliers that submit Communications, we store the supplier-specific SEE and version it so you can see which Communication applied to each quarter.
Free CN check for lookups; paid tier handles the full declaration workflow with version control and supplier data ingestion.
Published by Agonist Development AB. Not legal advice.