CBAM data for flat-rolled and coated steel exporters
Re-rollers and coating lines buy coil, process it and ship it on. Your figure is mostly your supplier's, plus the fuel your lines burn.
Quick answer
Flat-rolled steel, including hot-rolled, cold-rolled, galvanised and colour-coated products (CN 7208 to 7212), is covered by CBAM. Count fuel in reheating, annealing, galvanising and coating furnaces, plus the embedded emissions of the slab or coil you buy. Zinc and paint aren't precursors.
Is this product covered by CBAM?
Yes. Flat-rolled products of iron or non-alloy steel, whether hot-rolled (7208), cold-rolled (7209) or clad, plated or coated such as galvanised and colour-coated (7210, 7212), including narrow strip (7211), are within CBAM's iron and steel sector.
| CN code | Goods |
|---|---|
| 7208 | Hot-rolled flat products, 600 mm or wider |
| 7209 | Cold-rolled flat products, 600 mm or wider |
| 7210 / 7212 | Clad, plated or coated flat products |
| 7211 | Flat products under 600 mm wide |
Always confirm the exact code your buyer declares your goods under. Scope is set by CN code, not by how the product is described.
What counts toward your figure
Most iron and steel goods are on the CBAM list where only direct emissions count in the definitive period. Electricity used in your plant isn't part of the CBAM figure, even if the template asks you to report it.
Direct emissions at a typical rolling or coating line come from:
- Slab reheating furnaces (hot rolling)
- Batch or continuous annealing furnaces
- Galvanising line furnaces and zinc bath heating
- Colour-coating curing ovens
Your precursors: usually the biggest number
Hot-rolling mills roll slab; cold-rolling and coating lines process hot-rolled or cold-rolled coil. These precursors are CBAM goods with their producers' embedded emissions. Paints and zinc aren't CBAM precursors.
What your buyer will ask for
- Embedded emissions per tonne for each product code
- Route: hot rolling, cold rolling, coating
- Slab or coil suppliers and countries of origin
- Whether data is actual and verified
Documents to gather
- Fuel invoices and meter readings per line
- Production by product and line
- Slab and coil purchase invoices
- Yield and scrap records
Common mistakes
- One figure for hot-rolled, cold-rolled and coated products
- Counting electricity for rolling
- Missing the embedded emissions of bought coil
- Treating zinc or paint as precursors
For the full method, see how to fill in the CBAM communication template and default values vs actual emissions.
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Send your requestFrequently asked questions
Is galvanised steel covered by CBAM?
Yes. Coated flat-rolled steel, including galvanised and colour-coated products (CN 7210 and 7212), is covered.
I buy hot coil and cold-roll it. What is my precursor?
The hot-rolled coil, with its producer's embedded emissions or the default value.
Does zinc count as a precursor?
No. Fuel for heating the zinc bath counts as your direct emissions.
Sources
- European Commission: CBAM definitive regime
- European Commission: CBAM communication and news (guidance, templates, default values)
- EUR-Lex: summary of the CBAM Regulation (EU) 2023/956
This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.