Figure 2
Reporting CBAM actual emissions will benefit most importers As the verification process for actual emissions becomes clearer, we modelled CO 2 emissions for selected stainless steel producers. The CBAM regulatory framework considers stainless steel a complex good. Calculating CO 2 emissions requires accounting for both direct emissions generated during production and emissions embedded in precursors used in the production process.
Total Emissions = Direct Emissions + ∑( Embedded Emissions of Precursors)
Our model assumptions include 100 % ferrous scrap and primary alloys, based on CRU Nickel Market Outlook and CBAM publications on nickel and chrome.
Our analysis indicates that CO 2 emission costs for producing austenitic stainless steel( CR 304) using nickel-bearing material from Brazil( EUR 141 / t) or New Caledonia( EUR 160 / t) would be significantly lower than the lowest default values among key exporting countries, such as Japan( EUR 311 / t). Switching to Indonesian Nickel Pig Iron( NPI) as the primary nickel source raises emission costs substantially to EUR 380 / t, but this remains below default values for China, India, Taiwan( China) and
For CBAM stainless steel, this means summing direct production emissions with emissions from key raw materials – nickel and chrome. We modelled a standard EAF mill using the CRU Emissions Analysis Tool with varying nickel sources( Brazil, New Caledonia, Indonesia) as the highest emissionintensity component.
Figure 3
About CRU
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40 Stainless Steel World April 2026 www. stainless-steel-world. net