How to comply for this code
Reviewed by AutoCBAM team — last updated 2026-04-28.
Methodology guide -- CN 7209 (cold-rolled flat steel)
Cold-rolled coil is downstream of CN 7208 -- the supplier takes a hot-rolled coil and reduces its thickness through cold rolls. This adds about 10% to total emissions but creates the higher-grade automotive, appliance and construction surfaces that dominate EU imports.
Step 1 -- understand the integrated emissions picture. A typical Korean integrated mill producing CN 7209 reports 1.9-2.1 t CO2/t direct (carrying the BF-BOF upstream) + 0.4 t CO2/t indirect (cold mill electricity). The EU 1.88 + 0.275 default is low-side for this code.
Step 2 -- ask suppliers to disaggregate scope 1 and scope 2. Cold-rolling is electricity-intensive -- the indirect emissions factor is sensitive to the local grid. A Korean mill on the KEPCO grid (~0.45 kg CO2/kWh) emits about 0.4 t CO2/t indirect; a Japanese mill on the JEPIC grid (~0.43 kg CO2/kWh) is similar. A Chinese mill in Hebei (coal-heavy, ~0.65 kg CO2/kWh) is much higher.
Step 3 -- check for downstream allocation issues. When a supplier produces both hot-rolled and cold-rolled output from the same upstream mill, mass and energy must be allocated correctly. Reg. 2025/2621 Article 7 mandates physical-allocation-by-mass for cold rolls -- challenge supplier numbers that look proportionally too low for the cold-rolled split.
Step 4 -- track quarterly exposure with the calculator. CRC import economics are competitive on per-tonne CBAM cost -- ~€0.95/tonne in 2026 -- but the tonnage compounds. A 50,000-tonne annual program is €47.5k in 2026; €475k by 2034.
Step 5 -- supplier audit cadence. Verified-data certificates expire on supplier-defined cadences. Re-verify every 12 months and at any change of production route or grid electricity contract.