Is stainless steel covered by CBAM the same way as carbon steel?

Iron and steel fall within most positions of chapters 72 and 73 of the customs nomenclature, with notable exceptions for ferro-alloys (7202) and ferrous waste and scrap (7204). Seamless stainless tubes are explicitly covered, under CN codes 7304 11, 7304 22, 7304 24, 7304 41 and 7304 49 (subheadings dedicated to stainless steel); welded tubes fall under heading 7306, also covered. Steel and stainless steel fittings and flanges fall under heading 7307 (tube or pipe fittings of iron or steel), which is listed in Annex I of the regulation: they are covered on the same basis as tubes.

Are copper or nickel alloys covered by CBAM?

CBAM covers cement, electricity, fertilisers, hydrogen, aluminium, and iron and steel — not copper (chapter 74) or nickel (chapter 75): our copper-alloy (cupronickel, brass) tubes and fittings fall outside the regulation. One caveat on alloys marketed under a "nickel" name: customs classification decides, not the commercial name. An alloy where iron remains the predominant element — Alloy 800 (1.4876) or Alloy 825, for example — is classified under chapter 72 or 73 and therefore falls within CBAM scope; only alloys where nickel predominates (chapter 75) are excluded. When in doubt, we confirm the tariff classification before you order.

Does SPS handle my CBAM compliance for me?

No. The declaration and authorised declarant status are yours, as the importer. We supply the emissions and traceability data from our mills that feeds your declaration — we do not file it on your behalf.

What if I import less than 50 tonnes a year?

You are exempt from CBAM obligations for that year, under the 50-net-tonne cumulative de minimis threshold introduced by Regulation (EU) 2025/2083. Two points of vigilance: the exemption must be declared to customs (exemption code Y137), and crossing the threshold during the year makes you liable on the entire volume imported that year — not just the tonnes above the threshold. Cumulative tracking is therefore essential if you are close to the threshold.

When will I actually have to pay for CBAM certificates?

Not in 2026. Sales of certificates covering 2026 imports only open in February 2027, at the average auction price of the EU Emissions Trading System. From 2027 onward, a minimum quarterly stock obligation is added, set at 50% of embedded emissions accumulated since the start of the year. The cost is real but deferred: it is provisioned for, not paid at order time.

Where can I follow official CBAM updates?

On the dedicated CBAM pages of the European Commission and, for French importers, of the Direction générale des douanes et droits indirects (DGDDI).

MIS À JOUR LE 15 August 2026 · VÉRIFIÉ CONTRE Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083

STEEL REGULATION

CBAM: what the definitive regime requires since 2026

Since 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) has entered its definitive phase: authorised declarant status, purchase of carbon certificates, annual declaration. Iron and steel — including stainless — are among the sectors covered. As the importer, these obligations are yours.

What is the CBAM definitive regime, and since when?

CBAM moved from a transitional reporting-only phase (October 2023 to December 2025) to a definitive regime with financial obligations, effective 1 January 2026. Iron and steel alone accounted for 98% of CBAM-covered volumes in the first days of this definitive regime.

Source: European Commission — CBAM definitive regime entered into force on 1 January 2026 · verified 15 August 2026

Do you need authorised CBAM declarant status?

Yes, if you import more than 50 net tonnes of covered goods per year, cumulated. This single mass-based threshold, introduced by Regulation (EU) 2025/2083, exempts importers who stay below it. Above it, authorised declarant status is mandatory to import.

Source: EUR-Lex — Regulation (EU) 2025/2083, Article 2a and Annex VII · verified 15 August 2026

What if you do not yet hold your status on 1 January 2026?

A transitional provision of Regulation (EU) 2025/2083 lets you keep importing if your authorisation application was filed by 31 March 2026, while the competent authority decides — rather than an immediate import block.

Source: EUR-Lex — Regulation (EU) 2025/2083, Article 17(7a) · verified 15 August 2026

How is the CBAM certificate price calculated?

It tracks the average auction price of EU Emissions Trading System allowances — a quarterly average for 2026, then a weekly average from 2027 onward. It is not a fixed rate: it changes at every publication.

Source: European Commission — CBAM definitive regime, certificate price calculation · verified 15 August 2026

When is the annual CBAM declaration due?

By 30 September of the year following import — for the first time in 2027, for the year 2026. This deadline was postponed by Regulation (EU) 2025/2083, which also simplified declared-emissions calculations.

Source: EUR-Lex — Regulation (EU) 2025/2083, Article 6(1) · verified 15 August 2026

What SPS provides you

You import, so you are the party liable: authorised declarant status, embedded emissions, certificates to surrender. Our work starts upstream — documented origin, Melt & Pour traceability, emissions data from our mills, EN 10204 material certificates. That is what your customs broker will ask you for, and what we hand over with the goods.

And when one origin saves you on material price but costs you more in CBAM or safeguard duties, we tell you before you order.

Frequently asked questions

Is stainless steel covered by CBAM the same way as carbon steel?: Iron and steel fall within most positions of chapters 72 and 73 of the customs nomenclature, with notable exceptions for ferro-alloys (7202) and ferrous waste and scrap (7204). Seamless stainless tubes are explicitly covered, under CN codes 7304 11, 7304 22, 7304 24, 7304 41 and 7304 49 (subheadings dedicated to stainless steel); welded tubes fall under heading 7306, also covered. Steel and stainless steel fittings and flanges fall under heading 7307 (tube or pipe fittings of iron or steel), which is listed in Annex I of the regulation: they are covered on the same basis as tubes.; Source: EUR-Lex — Regulation (EU) 2023/956, Annex I · verified 15 August 2026
Are copper or nickel alloys covered by CBAM?: CBAM covers cement, electricity, fertilisers, hydrogen, aluminium, and iron and steel — not copper (chapter 74) or nickel (chapter 75): our copper-alloy (cupronickel, brass) tubes and fittings fall outside the regulation. One caveat on alloys marketed under a "nickel" name: customs classification decides, not the commercial name. An alloy where iron remains the predominant element — Alloy 800 (1.4876) or Alloy 825, for example — is classified under chapter 72 or 73 and therefore falls within CBAM scope; only alloys where nickel predominates (chapter 75) are excluded. When in doubt, we confirm the tariff classification before you order.; Source: EUR-Lex — Regulation (EU) 2023/956, Annex I · verified 15 August 2026
Does SPS handle my CBAM compliance for me?: No. The declaration and authorised declarant status are yours, as the importer. We supply the emissions and traceability data from our mills that feeds your declaration — we do not file it on your behalf.
What if I import less than 50 tonnes a year?: You are exempt from CBAM obligations for that year, under the 50-net-tonne cumulative de minimis threshold introduced by Regulation (EU) 2025/2083. Two points of vigilance: the exemption must be declared to customs (exemption code Y137), and crossing the threshold during the year makes you liable on the entire volume imported that year — not just the tonnes above the threshold. Cumulative tracking is therefore essential if you are close to the threshold.
When will I actually have to pay for CBAM certificates?: Not in 2026. Sales of certificates covering 2026 imports only open in February 2027, at the average auction price of the EU Emissions Trading System. From 2027 onward, a minimum quarterly stock obligation is added, set at 50% of embedded emissions accumulated since the start of the year. The cost is real but deferred: it is provisioned for, not paid at order time.
Where can I follow official CBAM updates?: On the dedicated CBAM pages of the European Commission and, for French importers, of the Direction générale des douanes et droits indirects (DGDDI).

Guillaume Roché

Partner

Published 15 August 2026 · Updated 15 August 2026