How to comply for this code
Methodology guide -- iron and steel
For iron and steel CN codes, the embedded emissions are dominated by the production route (BF-BOF integrated mill vs. EAF mini-mill). The 1.88 t CO2/t default value is conservative for EAF imports and aggressive for BF-BOF imports.
Step 1: classify the production route. Ask the supplier whether the product is from a blast-furnace + basic oxygen furnace (BF-BOF) line or from an electric-arc furnace (EAF). EAF emissions are typically 70-80% lower than BF-BOF.
Step 2: collect verified data. Request a CBAM communication template from each supplier. The EU Implementing Regulation 2025/2621 specifies the data points: scope 1 + scope 2 emissions per tonne of finished product, allocation method, and verifier accreditation ID.
Step 3: apply Article 9 deductions. If the producer's country has an explicit carbon price (e.g. UK ETS, EU ETS by way of installations covered, or national carbon tax), document the per-tonne carbon cost paid -- this deducts directly from your CBAM certificate obligation.
Step 4: monitor quarterly. Under Reg. 2025/2083 importers must hold 50% of projected certificates by end of each quarter from 2026. Run the calculator quarterly to track exposure.