Our EU buyer wants CBAM data for products that are not CBAM goods. Do we have to give it?

There is no CBAM duty for goods outside Annex I. The buyer may still want a carbon footprint for its own reporting, which is a commercial request. Confirm the CN code, explain it is not covered, and offer an ordinary product footprint instead.

Check first

• Confirm the CN code with your broker.
• Compare it with Annex I of the CBAM Regulation.
• Note whether downstream rules may extend the list.

Reply

Say the product is not a CBAM good under its code, and offer a footprint with method and period. Keep it separate from any CBAM figures you send for covered goods.

Why buyers ask

Many buyers request data for every steel or aluminium item, without checking codes first.

What Senseible does here

Senseible reads bills, fuel invoices and production records into dated, fingerprinted records, so the figure you send a buyer can be traced to its documents.

• Is steel furniture covered?
• Are pumps and bearings covered?
• Buyer questionnaire formats

Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM legislation and guidance

Last reviewed 2026-10-22.