Senseible

Does CBAM apply to used or second-hand steel and aluminium goods shipped to the EU?

Yes. The EU's CBAM Q&A 1.11 says CBAM applies to all goods listed in Annex I of the CBAM Regulation that are released for free circulation in the EU. Used steel structures, rails or aluminium profiles declared under a listed CN code are covered, however old they are.

Which figure the importer declares

For goods imported in 2026, the reporting period is set to 2026 by law, even if the goods were made years earlier. Q&A 5.20 adds that actual emissions cannot be given for goods produced before 1 January 2026, because no CBAM verification or accredited verifier existed then. For older used goods, that leaves the EU default values.

The 50-tonne threshold

The threshold counts the net mass under the CN code on the customs declaration, so used goods count toward an importer's 50 tonnes a year just as new ones do.

What to send the buyer

What Senseible does here

Senseible's CBAM cost calculator works out the cost of covered goods on EU default values for each year from 2026 to 2034, the case for used goods with no producer data.

Sources: European Commission, CBAM Questions and Answers (15 October 2026), question 1.11, 4.30 and 5.20, CBAM Regulation (EU) 2023/956, consolidated, Implementing Regulation (EU) 2025/2621, default values

Last reviewed 2026-11-01.