# We sell steel parts to an EU defence buyer. Are military goods exempt from CBAM?

Canonical: https://senseible.earth/answers/cbam-steel-sold-to-eu-military-covered

Usually not. Article 2(3)(c) of the CBAM Regulation exempts only goods moved or used in military activities under Article 1(49) of Delegated Regulation (EU) 2015/2446, which means movements between military forces. The EU's CBAM Q&A 1.13 says goods a company sells to EU military forces are subject to CBAM.

## What the exemption covers

- Goods moved between military forces, for example between NATO bases, in the activities Article 1(49) lists.
- These movements are declared on the NATO or EU Form 302, and goods declared that way are not subject to CBAM.
- If such goods are declared another way, the importer should state in the customs declaration that Article 2(3)(c) applies.

## What does not qualify

- A commercial sale by your company to an EU armed force.
- Goods imported by or for an EU country's military authorities but not for the activities in Article 1(49).

## What to prepare

Treat the order like any other CBAM shipment. Whoever imports it, a defence ministry or a prime contractor, will ask for the CN code, net mass and the embedded emissions of your installation, or will fall back on EU default values.

## What Senseible does here

Senseible reads your fuel and electricity bills into the installation records a defence importer will ask for, the same as for any EU buyer. It does not decide customs status.

- [CBAM for exporters](https://senseible.earth/cbam)
- [Who arranges the verification](https://senseible.earth/answers/who-arranges-cbam-verification-exporter-or-importer)
- [Are steel forgings covered](https://senseible.earth/answers/are-steel-forgings-covered-by-cbam)

Sources: [European Commission, CBAM Questions and Answers (15 October 2026), question 1.13](https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en?filename=CBAM_Questions%20and%20Answers.pdf), [CBAM Regulation (EU) 2023/956, consolidated](https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20)

Last reviewed 2026-11-01.