Is seafood, fish meal or shrimp feed a Carbon Border Adjustment Mechanism (CBAM) good, and what does Annex I list?

No. In the consolidated text of 20 October 2025, Annex I of the CBAM regulation lists cement, electricity, fertilisers, iron and steel, aluminium and hydrogen. It has no heading for fish, shellfish, fish preparations, fish meal or feed. A European Union (EU) buyer asking a seafood exporter for a footprint is not asking for CBAM.

What Annex I lists

• The consolidated regulation as it stood on 20 October 2025 groups Annex I under six headings: cement, electricity, fertilisers, iron and steel, aluminium, and chemicals, where the only entry is hydrogen (Combined Nomenclature (CN) code 2804 10 00).
• The CN headings in the annex sit in chapters 25, 26, 27, 28, 31, 72, 73 and 76. The original 2023 text has the same chapters.
• Chapter 3 (fish and crustaceans), chapter 16 (preparations of fish) and chapter 23 (food industry residues and prepared animal feed, where fish meal is classified in the CN structure) do not appear.

Two traps when you search the annex

• A word search for "fish" finds one hit: fish-plates, the steel joints in railway track, under CN 7302. It has nothing to do with seafood.
• The annex does list steel cans and boxes up to 300 litres (CN 7310), aluminium cans and boxes (CN 7612) and aluminium foil up to 0.2 mm thick (CN 7607) as goods in their own right. If you export those items by themselves, they are on the list. Whether the can or foil around a filled consignment of seafood counts is a customs classification question this page does not settle; ask your customs broker.

Why the buyer may still ask for numbers

An EU importer may ask for energy use, a footprint per kilogram or a supplier questionnaire answer for its own reporting. That is a buyer request, not a CBAM duty, and nothing in the regulation fixes its format. Answer it with your own bills and production log.

Check it yourself in five minutes

1. Find the CN code on your export invoice or shipping bill.
2. Open Annex I of Regulation (EU) 2023/956 on EUR-Lex and look for the first four digits.
3. If the digits are not there, the goods are not listed.
4. If the buyer still calls it a CBAM request, ask which law or questionnaire it comes from and what format it wants.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records, so a seafood plant can answer a buyer's footprint request from its own power and diesel records. Senseible does not decide customs classification, so confirm CN codes with your broker.

• Veraval seafood cluster: energy and CO2
• Carbon footprint per kg of frozen shrimp
• Fish feed carbon footprint
• CBAM overview
• Railway track materials and CBAM

Sources: Regulation (EU) 2023/956, consolidated text of 20 October 2025, Annex I, Regulation (EU) 2023/956, original text, Annex I

Last reviewed 2026-11-06. Annex I can be amended. Re-open the current consolidated text on EUR-Lex before you tell a buyer a product is out of scope.