Senseible

How does CBAM define carbon, low alloy, high alloy and stainless steel?

Stainless steel has 1.2% carbon or less and 10.5% chromium or more by weight. High alloy steel has 8% or more metallic alloying elements, or needs high surface quality and processability. Low alloy is other alloy steel. Carbon steel is everything else. The category and route select your free allocation benchmark.

The four definitions

Why the category matters

Some CN codes carry several benchmark values, and the right one depends on a letter code. The code is chosen from the steel category and the production route.

The letter codes

Where the route comes from

With actual data, you know your own route. With default values, the route is read from the last column of the Default Values Act table for the country and CN code, or from the 'Other countries and territories' table or Annex IV if the origin is unknown.

What Senseible does here

Senseible reads mill test certificates and purchase invoices into records of grade and quantity, which helps you sort goods by steel type. The category call itself comes from your product specification and verifier.

Sources: European Commission, CBAM Guidance No. 4, free allocation adjustment (14 August 2026), section 2.1.2 (steel category definitions) and Table 2-2 (route codes)

Last reviewed 2026-10-25.