Our steel is finished in another country before it reaches the EU. Which country counts for CBAM?

Two countries matter. Origin follows the EU's non-preferential rules of origin. Production is the country of the last physical processing, excluding packaging. For CBAM reporting, the production country decides whose installation reports the emissions and which default values apply. They are usually the same but can differ.

Country of origin

Set by the EU's non-preferential rules of origin in the Union Customs Code. It is the country on the customs declaration.

Country of production

The country where the last physical processing of the good took place, leaving out packaging. Only the operator of the installation that did that last step can work out the specific embedded emissions of the good. The country of production is also what identifies the default emission factor for imported electricity and for indirect emissions.

Why a job worker changes the picture

• If your coil is rolled or coated in another country, that last installation is the one whose emissions data the importer needs.
• If a contractor does the last step, you will need its emissions data and the production year of the goods.

Check before you quote

Ask your buyer which country it will declare as origin and which installation it expects data from.

What Senseible does here

Senseible reads your fuel, power and steam bills into verified emission records, so the monthly figures a monitoring plan needs are ready to hand to your verifier. Verified here means rule checks passed against the evidence. It is not third-party assurance, and a CBAM verifier still signs the report.

• Goods processed by a job worker before export
• CBAM CN code mismatch on shipping bill and declaration
• CBAM Suite

Sources: European Commission, CBAM Questions and Answers (definitive period)

Last reviewed 2026-11-04.