Ask the CBAM expert!
Confused by CBAM? Have a question you can’ t find the answer to? Ask our experts to find the answers you need …
Answer provided by Pauline Miquel, Policy & Research Lead, CBAMBOO
Scenario: An EU steel producer sells steel plates to a non-EU buyer. The non-EU buyer processes the steel( e. g., cuts, bends, or machines it into a steel part) and sells it to an EU buyer. This EU buyer must now purchase and surrender a CBAM certificate. For this, they can apply for a deduction based on the EU ETS carbon price already paid by the EU steel producer.
Question: Is the EU steel producer required to provide detailed data on its CO2 emissions for this steel? Or is it sufficient to provide a certificate of origin proving that the steel was melted and poured in the EU( and thereby already subject to the EU ETS)?
Answer: There are two separate areas to clarify in this scenario, with varying levels of regulatory certainty as of February 2026. This situation will continue to evolve as more implementation guidelines are published in the coming months.
1. Zero emissions attributed to precursors of EU-origin Following the adoption of the Omnibus regulation in October 2025, emissions embedded in a CBAM precursor( raw material such as a steel plate) produced in the EU carry no CBAM cost. These emissions are already priced under the EU ETS and should be attributed zero emissions to avoid double counting. This means a non-EU supplier should declare zero emissions for the steel plates purchased from an EU producer and used to produce the final product. However, while no CBAM cost will apply to this portion of emissions, it still needs to be reported as a zero-emission precursor to the company reimporting the final product into the EU. Furthermore, evidence of EU origin must be submitted to a verifier for these emissions to be effectively counted as zero. What remains unclear at this stage is the exact evidence required to demonstrate that the precursor was subject to the EU ETS. Currently available documentation clarifies the principle but does not define the documentation standard. In practice, it is reasonable to expect that proof of EU origin and confirmation that the steel was melted and poured in the EU- for example through mill certificates, commercial documentation, or supplier declarations- should be sufficient. However, until verification audits take place( after summer 2026) and further implementing guidelines are published, this point remains unclear.
2. Emissions reporting for non-EU processing activities CBAM costs should only apply to additional emissions arising from processing steps carried out outside the EU. However, some production steps considered“ finishing processes” are exempted from emission monitoring requirements.
a. Finishing processes( excluded from emissions monitoring) This applies to processes such as cutting, welding, or simple assembly of EU-origin steel plates. These activities do not require direct emission monitoring.“ Finishing processes” do not carry a carbon price in the EU, and consequently, their emissions should not be priced at the border either.
Instead of tracking emissions, installations performing finishing steps must record and report:
• Precursor inputs( quantities and embedded emissions of raw materials)
• Output volumes
• Scrap generation
Verification of these installations will focus on material flows and confirming the activities qualify as finishing processes, not on measuring emissions.
b. Production processes( included in emissions monitoring) However, if the non-EU processor performs more substantial transformations such as bending, forging, forming, machining, or heat treatment, these activities fall within CBAM’ s scope. Direct emissions from fuel or gas used in these processes must be reported using actual measurements or default values. Indirect emissions( electricity) do not need to be reported for steel products except for sintered ore.
About the expert
Pauline Miquel is Policy & Research Lead at CBAMBOO. Her work focuses on monitoring regulatory evolutions across jurisdictions, external affairs, and public-facing content creation. She holds a dual MSc in Environmental Economics and Climate Change from PKU and LSE, with research focused on CBAM implications for the steel industry.
Send your questions to the Editor, Joanne McIntyre, at: j. mcintyre @ kci-world. com
36 Stainless Steel World March 2026 www. stainless-steel-world. net