Is pre-consumer steel scrap also zero emissions under CBAM, or only post-consumer?

The two EU guides word it differently. The steel guide's footnote says where only post-consumer scrap is used, it is assumed to have zero embedded emissions. The aluminium guide says scrap, whether pre-consumer or post-consumer, has zero. The steel footnote prints no pre-consumer rule, so record the split and ask your verifier.

What each guide prints

• Steel guide, section 2.2.3.7 (electric arc furnace), footnote 10: 'Where only post-consumer scrap is used, it is assumed to have zero embedded emissions.'
• Aluminium guide, section 2.2.3.2 (secondary melting): 'Scrap (whether pre-consumer or post-consumer) is treated as a raw material and so has zero embedded emissions.'

What else the guides say about scrap

• Guidance No. 3 says scrap and waste leaving a production process have zero embedded emissions, so that all attributed emissions sit on the saleable goods.
• Example 2 in Guidance No. 3 calls steel scrap 'not a precursor'.
• The steel reporting table still asks for the percentage of scrap that is pre-consumer. My reading: the split matters to the buyer's declaration, which is why it is worth recording.

What this page cannot settle

This page reads the Commission's guides, not the legal act behind them. The steel footnote does not say what happens when some of the scrap is pre-consumer. The guides do not print a stricter rule for pre-consumer steel scrap, but the footnote is narrower than the aluminium sentence. The rule in the Commission's legal act for the year you export decides.

What to do now

1. Record every scrap lot as pre-consumer or post-consumer at the weighbridge.
2. Keep the monthly split with your furnace charge sheets.
3. Ask your buyer and your verifier, in writing, how they treat the pre-consumer part, and keep the answer.

Example: a scrap register for one month

• Scrap in: 1,000 tonnes. Post-consumer yard scrap: 800 tonnes. Offcuts from a press shop: 200 tonnes.
• Pre-consumer share: 200 / 1,000 = 20%
• The steel footnote's sentence plainly covers the 800 tonnes. It is silent on the 200.

Example tonnes. This shows what to record. It is not a ruling on how the 200 tonnes are treated.

What Senseible does here

Senseible reads fuel and electricity bills into dated, fingerprinted records. Scrap lots and the pre-consumer split stay in your own register. Senseible does not verify a CBAM figure.

• Is scrap zero under CBAM
• Finding scrap tonnes per tonne
• Secondary aluminium: decoating and dross fuel
• Sponge iron and induction furnace billets
• CBAM readiness for exporters

Sources: European Commission, CBAM Guidance No. 5d, iron and steel (14 August 2026), European Commission, CBAM Guidance No. 5e, aluminium (14 August 2026), European Commission, CBAM Guidance No. 3, methods for calculating embedded emissions (14 August 2026)

Last reviewed 2026-11-07. Quotes are word for word from Guidance No. 5d (footnote 10) and No. 5e (section 2.2.3.2), 14 August 2026; the scrap and waste lines are from Guidance No. 3, section 4.9.1.1, and its Example 2. This page reads the Commission's guides, not the legal act behind them. Check the current rule before relying on it. The live page 'Is scrap zero under CBAM' hedges that the definitive rule should be checked, and the live induction furnace page says the EU has proposed counting pre-consumer scrap; neither is contradicted, and this page adds only what the guides print.