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Data Checklist for Iron or Steel Products

Updated over 3 weeks ago

This checklist helps non-EU suppliers and exporters understand which data points are relevant for calculating CBAM emissions for the aggregated goods category "Iron or Steel Products".


🔍 Step 1: Identify Your Product and CN Code

What to do: Find out if your product falls under the aggregated goods category of iron or steel products.

Why it matters: CBAM compliance requires specific data based on your product type, and the CN code helps you determine what data to collect.

How to proceed:

  • Refer to the EU's official CBAM guidance or CN code database.

  • Look up your product type and confirm its classification under the “Iron or Steel Products” AGC.

  • CN codes typically start with 72 or 73 for iron or steel products (e.g., 7308 90 98 for steel structures).

  • Write down the correct CN code. This will guide your emissions data requirements.


🛠️ Step 2: Identify Precursors

What to do: Determine which raw materials or intermediate products go into manufacturing your iron or steel product.

Why it matters: Understanding your inputs is essential for accurate calculation of embedded emissions.

How to proceed:

  • List all precursor materials, such as crude steel, pig iron, DRI or ferro-alloys.

  • Contact your suppliers to obtain emissions data for each precursor. If supplier data isn’t available, use EU-approved default values (based on CN codes).

  • Record the quantities and types of each material used in your product.


Step 3: Track Energy and Fuel Consumption

What to do: Measure the energy and fuel used during the manufacturing process.

Why it matters: These inputs directly affect your product’s total emissions and are required for CBAM reporting.

How to proceed:

  • Document electricity consumption in kilowatt-hours (kWh), specifying the electricity source:

    • Grid default

    • Direct connection to a generator

    • Power Purchase Agreement (PPA)

  • Record all fuel types used (e.g., coke, natural gas, diesel) and their consumption levels.

  • Maintain this data for the entire reporting period.


📦 Step 4: Record Product Output Quantities

What to do: Log the total amount of iron or steel product you manufacture.

Why it matters: Emissions must be calculated per tonne of product, so accurate output data is vital.

How to proceed:

  • Record the total tonnage of finished iron or steel products during the reporting period.

  • Note any further processing (e.g., rolling, coating) that could impact emissions.

  • If relevant, document the presence of alloying materials and their respective proportions.


📝 Checklist Summary for Action

  • Identify Product and CN Code – Confirm your product’s CN code to determine required data.

  • Identify and Track Precursors – List and document all raw materials and their emissions data.

  • Track Energy and Fuel Use – Monitor and record energy and fuel inputs across the production process.

  • Monitor Outputs – Keep accurate records of all product output quantities, including alloy

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