[SMM Stainless Steel Flash] EC Publishes Steel CBAM Guidance, Clarifying Stainless Steel Emissions Rules
The European Commission has published sector-specific CBAM guidance for iron and steel, providing detailed rules on calculating and monitoring embedded emissions during the definitive period from 2026. Steel imports are divided into six aggregated goods categories: sintered ore, ferro-alloys, pig iron, DRI, crude steel, and iron or steel products. Only direct emissions are generally included for steel products, with sintered ore (CN 2601 12 00) as the exception requiring indirect electricity emissions. For EAF-based steelmaking, electricity-related emissions are excluded from crude steel embedded emissions calculations. For stainless steel produced via the EAF/AOD route, embedded emissions are calculated at 1.783 mt CO₂/mt; a hypothetical 2027 import of 100mt of stainless steel results in an obligation to surrender 95.9 CBAM certificates after the free-allocation adjustment. Material losses from cutting and machining increase embedded emissions per tonne of finished goods, with stainless steel screws and nuts reaching 2.371 mt CO₂/mt. The guidance is explanatory rather than legally binding, with applicable EU legislation taking precedence.