Senseible

We make 304 and 316 stainless under one CN code. Do we need a separate CBAM figure per grade?

No. The EU's CBAM Q&A 6.6 says embedded emissions are worked out per CN code, the default functional unit in Article 4 of Implementing Regulation (EU) 2025/2547. Alloy content and scrap share can vary within that code, so 304 and 316 made under the same CN code share one figure.

What sets the number of figures

What the grade still changes

Example: stainless bars, one CN code, one year

Example figures.

What Senseible does here

Senseible's CBAM Suite builds one figure per CN code and carries ferro-alloy purchases in as precursors from your invoices. We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them.

Sources: European Commission, CBAM Questions and Answers (15 October 2026), question 6.6, European Commission, CBAM Guidance No. 5d, iron and steel (14 August 2026), section 3.1.3 and worked examples 2 and 3, European Commission, CBAM Guidance No. 5e, aluminium (14 August 2026), section 4

Last reviewed 2026-11-01.