Besides the emissions figure, what extra data must an Indian steel exporter give its UK importer?
HMRC's technical guidance, Table 5-11, says the emissions data you send a UK importer for iron or steel products should add: mass % of manganese, chromium, nickel, silicon and other alloy elements, tonnes of scrap per tonne of product, the share of that scrap that is pre-consumer, and the main reducing agent used in precursor production, if known.
What to add, by product
- Iron or steel products: mass % of Mn, Cr, Ni, Si and total other alloy elements; tonnes of scrap per tonne of product; % of that scrap that is pre-consumer; main reducing agent used in precursor production, if known.
- Crude steel: the same, with scrap per tonne of crude steel and the main reducing agent of the precursor, if known.
- DRI (sponge iron): main reducing agent used; mass % of Mn, Cr, Ni, Si and total other alloy elements.
- Pig iron: main reducing agent used; mass % of Mn, Cr, Ni and total other alloy elements.
- Ferro-manganese, ferro-chromium, ferro-nickel: mass % of the main metal and of carbon.
- Sintered ore: nothing extra.
Why your importer asks
HMRC says the operator needs to collect these parameters for its CBAM goods and pass them on, because the importer will need to report them when the goods are imported under UK CBAM. A figure without them leaves your importer's return incomplete.
Where the numbers sit in your plant
- Alloy content: the heat analysis on your mill test certificate.
- Scrap tonnes: scrap purchase and yard records against tonnes of finished product for the same period.
- Pre-consumer share: offcuts and rejects from manufacturing, as against post-consumer scrap from used products. Ask scrap suppliers to state which on their invoices, and keep the two apart in the yard.
- Reducing agent: coal for coal-based sponge iron, natural gas for gas-based. If you buy sponge iron or pig iron and do not know, HMRC asks for it only if known.
Example: an induction furnace mill, one month of TMT bars
- Charge: 1,200 t scrap, of which 300 t factory offcuts, plus 600 t coal-based sponge iron
- Output: 1,650 t of bars
- Scrap per tonne of product: 1,200 / 1,650 = 0.73 t
- Pre-consumer share: 300 / 1,200 = 25%
- Main reducing agent in precursor production: coal
- Alloy content from heat analysis, for example Mn 0.55%, Si 0.20%, Cr 0.05%, Ni 0.03%
All tonnages and chemistry are example values.
What Senseible does here
Senseible reads scrap, sponge iron, pig iron and ferro-alloy purchase invoices, so scrap tonnes per tonne of product come from documents you can show. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
- CBAM report from your records
- Records your UK buyer will ask for
- UK CBAM rebar and wire rod defaults
- Scrap and UK CBAM
Last reviewed 2026-11-03. HMRC is taking feedback on this guidance until 13 November 2026 and may update it before 1 January 2027.