Our Batam yard fabricates steel structures for an EU project. Are they CBAM goods?
Yes. Steel structures under CN 7308 are CBAM goods. Your figure is the yard's own direct emissions, such as fuel for cutting, welding gases and painting ovens, plus the embedded emissions of the plates, sections and tubes bought in, which usually dominate.
What counts
- Embedded emissions of purchased steel, from each mill or a default value.
- Fuel burnt in the yard: gas cutting, preheating, ovens.
- Electricity is not counted for steel goods.
Records the importer needs
- Mill certificates linking each plate or section to a mill.
- Tonnes of each input per shipped structure.
- Fuel use for the period.
Offcuts
Steel cut away and scrapped still came in with its embedded emissions, so the figure per tonne shipped rises with waste.
What Senseible does here
Senseible reads fuel, electricity and production documents into dated, fingerprinted installation records, the starting point for the actual emissions an EU importer asks for.
Sources: CBAM Regulation (EU) 2023/956, consolidated, Implementing Regulation (EU) 2023/1773, monitoring rules, European Commission, CBAM legislation and guidance
Last reviewed 2026-10-22.