CBAM data for steel structure fabricators
Fabricators combine sections, plates and tubes from different mills. Under CBAM, each one brings its own embedded emissions into your product.
Quick answer
Steel structures and parts (CN 7308) are CBAM goods. A fabricator's own direct emissions are small, mainly from cutting gases and coating. Most of the figure comes from the plates, sections and tubes you buy, so track each by supplier and country of origin.
Is this product covered by CBAM?
Yes. Structures and parts of structures of iron or steel, such as bridge sections, towers, frames and columns, fall under CN heading 7308, which is within CBAM's iron and steel sector.
| CN code | Goods |
|---|---|
| 7308 | Steel structures and parts of structures |
| 7208 / 7216 / 7306 | Plate, sections and tubes, common precursors |
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 fabrication shop come from:
- Fuel gases for cutting and pre-heating
- Galvanising bath heating, if in-house
- Paint curing and drying ovens, if fuel-fired
Your precursors: usually the biggest number
Plates, sections, bars and tubes you buy are CBAM goods, each with its producer's embedded emissions. Fabricators often buy from several mills in several countries, so track tonnes by supplier and product type, and match them to what goes into each structure.
What your buyer will ask for
- Embedded emissions per tonne of structure
- A breakdown of precursor steel by type, supplier and country
- Your own fuel-related emissions
- Yield from purchased steel to shipped structure
Documents to gather
- Purchase invoices and mill certificates for all steel
- Fuel and gas invoices
- Project or order records linking steel to products
- Offcut and scrap records
Common mistakes
- Using one average for steel from very different mills
- Ignoring offcuts when relating input tonnes to output
- Counting bolts and fasteners without checking their own code
- Including electricity for welding and cutting machines
For the full method, see how to fill in the CBAM communication template and default values vs actual emissions.
Got a request you're not sure about?
Send us what your buyer sent. We'll tell you what they need and what it will take, free, within one week.
Send your requestFrequently asked questions
Are steel structures covered by CBAM?
Yes. Structures and parts of structures of iron or steel (CN 7308) are CBAM goods.
What if I buy steel from several mills?
Track tonnes by supplier, product and country. Each precursor carries its own embedded emissions or default value.
Does welding count?
Electricity for welding doesn't count. Fuel gases used on site do.
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.