CBAM data for stainless steel exporters

Stainless producers mix scrap, ferro-alloys and bought semi-finished steel. Getting the inputs right matters more than anything else.

Reviewed by the Carbon Passport compliance team, Singapore. Updated and checked against official EU sources on 28 September 2026. Rules change often; we update this page when they do.

Quick answer

Stainless steel in ingots, semi-finished, flat, bar, rod and wire forms (CN 7218 to 7223) is covered by CBAM. Melt shops count fuels, electrodes and process emissions, not electricity. Some ferro-alloys and bought semi-finished stainless are precursors with their own embedded emissions.

Is this product covered by CBAM?

Yes. Stainless steel in ingots and semi-finished forms (7218), flat-rolled products (7219, 7220), bars and rods (7221, 7222) and wire (7223) is within CBAM's iron and steel sector.

CN codeGoods
7218Stainless ingots and semi-finished products
7219 / 7220Stainless flat-rolled products
7221 / 7222Stainless bars, rods and sections
7223Stainless wire

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 stainless melt shop or processing mill come from:

  • Electrode consumption and carbon inputs in electric arc furnaces
  • Fuels in ladle heating, reheating and annealing
  • Process emissions from refining steps

Your precursors: usually the biggest number

Melt shops use scrap, which currently counts as zero, and ferro-alloys, some of which are CBAM goods with their own embedded emissions. Re-rollers and wire makers buy slab, coil or rod, which carry their producers' figures. Record every input by supplier and country.

What your buyer will ask for

  1. Embedded emissions per tonne for each stainless product code
  2. Production route and melt-shop inputs
  3. Ferro-alloy and semi-finished steel suppliers and origins
  4. Whether data is actual and verified

Documents to gather

  • Fuel, electrode and carbon input records
  • Heat logs and production by grade
  • Ferro-alloy, slab and coil purchase invoices
  • Scrap purchase and internal return records

Common mistakes

  • Leaving out ferro-alloy precursors
  • Counting EAF electricity as direct emissions
  • One figure for all grades and routes

For the full method, see how to fill in the CBAM communication template and default values vs actual emissions.

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Frequently asked questions

Is stainless steel covered by CBAM?

Yes. Stainless ingots, semi-finished products, flat products, bars, rods and wire (CN 7218 to 7223) are CBAM goods.

Do ferro-alloys count?

Some ferro-alloys are CBAM goods and count as precursors with their own embedded emissions. Check which ones you use.

Does EAF electricity count?

No. Most iron and steel goods count direct emissions only, so electricity isn't part of the CBAM figure.

Sources

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.

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