Steel and Aluminum Exporters: CBAM Compliance Checklist
Published 2025-01-15.
Steel and aluminum are priority sectors under EU CBAM. If you export to Europe, compliance preparation must start now.
Why Steel and Aluminum First:
- High carbon intensity, especially for blast-furnace steel and primary aluminium
- Significant trade volume to EU
- Clear emission measurement methodologies
- Direct competition with EU producers facing carbon costs
CBAM Compliance Checklist:
□ Data Infrastructure:
- Track fuel consumption by production process
- Monitor electricity use per unit produced
- Record raw material inputs and origins
- Implement document management system
□ Emission Calculations:
- Calculate Scope 1 (direct from fuel combustion)
- Calculate Scope 2 (from purchased electricity)
- Determine embedded emissions per product
- Apply correct emission factors (IPCC or verified)
□ Reporting Capability:
- Quarterly reports were filed by EU importers during the transitional period (October 2023 to end 2025)
- From 2026, EU authorised declarants file annual CBAM declarations (the first, for 2026 imports, is due 30 September 2027) using verified actual emissions or default values
- Data available for EU importer requests
□ Verification Readiness:
- Third-party verification capability
- Audit trail for all calculations
- Documentation of methodology
Your Action Items:
- Baseline current emissions from existing data
- Identify emission intensity per product
- Compare to EU benchmarks
- Plan reduction investments
Explore CBAM preparation details and start building your carbon verification capability.
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