The EU buyer wants tonnes of scrap per tonne of steel and the pre-consumer share. How do we work them out?

Divide the scrap you charged by the saleable tonnes it made, and split that scrap by where it came from. That division is my reading. The EU guide treats these as quality information about your goods: lab analysis where needed, or a mass balance of process inputs where that suits better, with the method written in the monitoring plan.

What the buyer is asking for

The guides say the importer reports these in the annual CBAM declaration, so you must collect them and pass them on.

• Steel, crude steel: tonnes scrap used for producing 1 tonne of crude steel, and the percentage of that scrap that is pre-consumer scrap.
• Steel, iron or steel products: the same two numbers per tonne of the product.
• Aluminium, unwrought aluminium and aluminium products: tonnes of scrap used for producing one tonne, and the percentage that is pre-consumer. If the total content of elements other than aluminium exceeds 1%, the total percentage of such elements too.

What pre-consumer means

My reading: pre-consumer scrap is offcuts and rejects from factories, before a product ever reached a user. Post-consumer scrap is old goods collected after use. The guides do not define the words, so ask your verifier which records they accept for the split.

How the guide says to get such numbers

Guidance No. 3 says these are quality information on goods, so the rules for calculation factors apply in principle. That means, where relevant, lab analyses may have to be carried out. In many cases such analyses are done anyway for quality control. In some cases it may be more appropriate to calculate the parameter from a mass balance of process inputs.

It assumes the parameters can be determined without unreasonable effort. The methods must be in the monitoring plan, which must be regularly reviewed.

Records that make the numbers easy to defend

• Scrap purchase invoices and weighbridge slips, with a column for the type of scrap.
• Furnace charge sheets showing tonnes charged by heat.
• Saleable tonnes of billets or products for the same period.

Example: one month in an arc furnace shop

• Scrap charged (all bought in): 1,150 tonnes. Of that, 230 tonnes are offcuts from a press shop, 920 tonnes were collected after use.
• Saleable billets: 1,000 tonnes
• Scrap per tonne: 1,150 / 1,000 = 1.15 tonnes
• Pre-consumer share: 230 / 1,150 = 20%

Example tonnes. The guide does not print this division, so confirm it with your verifier. Scrap from your own mill is left out here for simplicity.

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.

• What a CBAM verifier checks at a steel plant
• What a CBAM verifier checks at an aluminium plant
• Is scrap zero under CBAM
• Pre-consumer steel scrap in the EU guides
• CBAM readiness for exporters

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

Last reviewed 2026-11-07. The buyer's list is from Guidance No. 5d Table 3-1 and No. 5e Table 3-4 (both 14 August 2026). The how-to paragraph is from Guidance No. 3, section 4.9.1.2, 'Monitoring the quality of goods'. The division of scrap by saleable tonnes and the everyday meaning of pre-consumer are my reading and are marked so, because the guides do not print them in the parts read. Sums checked again: 920 + 230 = 1,150; 1,150 / 1,000 = 1.15; 230 / 1,150 = 0.20. The live verifier pages list these numbers in one line each; this page adds how to get them.