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Question: Our company is registered in both Bulgaria and Poland, and we import various products into the EU. We have completed the CBAM registration process and obtained our registry number. As an importer of goods under the CN code 7309 from Ukraine( metal containers), we are facing questions regarding the calculation and reporting of embedded carbon emissions. The production site purchases ready-made metal and performs cutting and welding in accordance with our drawings. Should we only include the emissions directly related to the welding and processing operations( as provided by the manufacturer)? Or must we also account for the emissions embedded in the purchased metal itself?
Answer: As an EU importer of goods classified under CN code 7309 00( reservoirs, tanks, vats and similar containers of iron or steel), your CBAM reporting and financial obligations have applied in full since 1 January 2026. CN 7309 falls within the iron and steel aggregated goods category and is classified as a complex good, so the embedded emissions you must report include not only the direct emissions from the production process at the Ukrainian installation, but also the embedded emissions of the precursor material. In this case, the steel coil or sheet that the Ukrainian facility purchases and processes according to your drawings is a precursor material.
What part of the embedded emissions carry a CBAM cost?
The Ukrainian installation’ s production process, cutting and welding, sits within the system boundary for iron and steel goods under CBAM. However, following the Omnibus simplification introduced by Regulation( EU) 2025 / 2083 in October 2025, these finishing activities are effectively assigned zero embedded emissions for CBAM purposes. It is important to note that this exclusion applies specifically to finishing operations. If the non-EU processor performs more substantial transformations such as bending, forging, forming, machining, or heat treatment, those activities fall within CBAM’ s scope and must be accounted for accordingly. The carbon intensity of the final product is therefore determined primarily by the upstream steel mill and its production route, not by Ukraine as a country of origin for finishing processes. The practical implication is significant. If it originates from a high-carbon production route such as a coal-based blast furnace rather than an electric arc furnace, the embedded emissions attributable to your imported containers could be substantial, even though the Ukrainian facility itself performs only light processing.
What the installation in Ukraine should do
The installation in Ukraine must identify the steel mill supplying its raw material and obtain that mill’ s specific embedded emissions per tonne of product, along with documentation of the production process. This is used to calculate the Specific Embedded Free Allocation( SEFA), also referred to as the benchmark, a measure of how much of the imported emissions are covered by CBAM in line with the policy’ s gradual phase-in schedule. This data must be calculated in accordance with the CBAM methodology and communicated to the Ukrainian processor, who in turn passes it on to you as the EU importer. Critically, for this data to be usable in your CBAM declaration, it must be verified by an accredited third-party verifier. If a supplier does not obtain verification- or fails it- their actual emissions data cannot be used, and the EU’ s official default values will apply instead. Default values are set by country of origin and production route, and carry a punitive mark-up: 10 % in 2026, 20 % in 2027, and 30 % from 2028 onwards. This escalating cost provides a strong commercial incentive to work proactively with your supply chain to collect reliable, verified data rather than fall back on conservative defaults.
What you, as a CBAM declarant, should do
As the authorised CBAM declarant, you are responsible for the accuracy of the reported embedded emissions across your entire supply chain. You must track this information from the upstream steel mill through to the Ukrainian processor and ensure it is correctly incorporated into your annual CBAM declaration. The first declaration, covering 2026 imports, is due by 30 September 2027. From February 2027, you will have to purchase CBAM certificates covering imported emissions. The most important practical step you can take now is to work with your Ukrainian supplier to identify the source steel mill, ensure the mill has a monitoring plan and is working to get a verified emissions report. This information then needs to be part of a robust, repeatable data-sharing process.
About the expert
Pauline Miquel is Policy & Research Lead at CBAMBOO, a leading independent specialist for CBAM management and policy, combining advisory and software services to simplify compliance, analyse risk, and minimise CBAM costs. Its services cover training, legislative analysis, policy updates, supplier and third-party engagement, and the sharing of best practices. Its software supports internal reporting of CBAM exposure for commercial and financial teams, provides forecasting tools to inform pricing decisions, and streamlines the compliance process end-to-end.
38 Stainless Steel World April 2026 www. stainless-steel-world. net