Which of our finishing steps are inside the CBAM boundary: pickling, galvanising, plating, cutting or welding?

Inside the EU CBAM boundary for iron and steel products: re-heating, re-melting, casting, hot and cold rolling, forging, pickling, annealing, coating, galvanising and wire drawing. Outside: plating, cutting, welding and finishing. Work done at another site and returned counts as if done at yours.

Inside the boundary

• Re-heating, re-melting and casting
• Hot rolling and cold rolling
• Forging
• Pickling and annealing
• Coating and galvanising
• Wire drawing

Outside the boundary

• Plating
• Cutting
• Welding
• Finishing of iron or steel products

Aluminium products are simpler

Everything directly or indirectly linked to the production process is inside, except cutting, welding and finishing of aluminium products.

Job work and second sites

If a step runs in a secondary installation, or a contractor does it and the goods come back to your primary installation, treat it as if it happened in your installation. Its fuel and electricity go into your figure, so you need the contractor to share them.

A galvanising line outside your gate does not leave the boundary. A cutting shop outside your gate was never in it.

What to collect

• Fuel and electricity for each inside step, per month.
• Job-work invoices with the quantity processed.
• A note of each outside step, so the verifier sees it was left out on purpose.

What Senseible does here

Senseible reads fuel and electricity bills into a dated record per site, so the inside steps can be totalled and the outside ones kept out.

• Galvanised and coated sheet under CN 7210
• Lime kilns and coke ovens are outside
• CBAM data for exporters

Sources: European Commission, CBAM Questions and Answers (updated 15 October 2026), Q&A 4.31

Last reviewed 2026-11-03. The EU keeps updating the Questions and Answers; check the current version before sending figures.