Which goods fall under CBAM: the CN-code product groups and how to check an import

CBAM applies to a closed list of goods set out in Annex I to Regulation (EU) 2023/956, arranged in six families: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen. What governs legally is not the family name but the Combined Nomenclature (CN) code: Annex I provides that the mechanism applies to goods falling under the CN codes set out in its table, using the nomenclature of Regulation (EEC) No 2658/87. Article 2(1) then fixes the trigger — the Regulation applies to those Annex I goods originating in a third country when they are imported into the customs territory of the Union, including processed products resulting from inward processing. Because the list is drawn at code level, several entries sit outside what the sector label suggests: the cement group reaches kaolinic clays (2507 00 80), and the iron and steel group extends to agglomerated iron ores (2601 12 00) and to finished articles in chapter 73. The reliable scope test is therefore the code you declare, not the commercial description of the shipment.

In Annex I the groups are populated as follows. Cement covers heading 2523 — clinker, white and other Portland cement, aluminous cement and other hydraulic cements — together with kaolinic clays under 2507 00 80. Electricity is a single line, 2716 00 00. Fertilisers span nitric acid (2808 00 00), ammonia (2814), potassium nitrate (2834 21 00), nitrogenous fertilisers (3102) and NPK-type fertilisers (3105), the last excluding phosphorus-and-potassium-only products under 3105 60 00. Iron and steel takes the whole of chapter 72 except the ferro-alloys of subheading 7202 and ferrous waste and scrap (7204), and adds specified articles of chapter 73 (headings 7301 to 7311, plus 7318 and 7326). Aluminium runs from unwrought metal (7601) through a defined set of semi-fabricated and finished-product headings between 7603 and 7616. Hydrogen appears not under a 'hydrogen' header but under a 'Chemicals' heading, as 2804 10 00. The greenhouse gases attributed to each group also differ — carbon dioxide throughout, with nitrous oxide added for fertilisers and perfluorocarbons for aluminium — a distinction that later shapes the embedded-emissions data an importer must obtain.

For a given shipment the test is mechanical but has traps. First, take the eight-digit CN code you declare to customs. Second, match it against the Annex I table, respecting the explicit carve-outs: the ferro-alloys of 7202 and ferrous scrap (7204) fall outside the iron and steel group, and phosphorus-and-potassium fertiliser (3105 60 00) outside the fertiliser group, even though adjacent codes are in scope. Third, check origin — Article 2(4) removes goods originating in Iceland, Liechtenstein, Norway and Switzerland, and in the territories of Büsingen, Heligoland, Livigno, Ceuta and Melilla, because those origins are covered by or linked to the EU ETS. A shipment therefore likely qualifies only where its code is listed and its origin is a third country not on that Annex III list; a product outside the code list stays out, however carbon-intensive the material. One data nuance follows for goods that do qualify: Annex II names a subset of iron, steel and aluminium codes for which, under Article 7(1), only direct emissions are counted — a point that affects the emissions figures you must collect, not whether the good is in scope.

Being in scope is not the same as being fully obligated. Article 2a, inserted by Regulation (EU) 2025/2083 and applicable from 1 January 2026, exempts an importer whose CBAM goods do not cumulatively exceed a single mass-based threshold in a calendar year; Annex VII point 1 sets that threshold at 50 tonnes of net mass. It is one figure applied to the total net mass under all relevant CN codes, aggregated per importer and per year across the four solid-goods sectors — iron and steel, aluminium, fertilisers and cement. Cross it, and the importer becomes subject to all obligations in respect of all emissions embedded in all goods imported that calendar year, so the exemption is lost for the whole year rather than only the excess. Critically, Article 2a(4) states that the exemption does not apply to imports of electricity or hydrogen: those two groups remain in scope from the first unit, whatever the mass — consistent with electricity being measured in megawatt-hours rather than tonnes. The Commission estimates the threshold releases roughly 182,000 importers, mostly SMEs, while keeping more than 99% of embedded emissions within CBAM, and it must review the figure by 30 April each year and may adjust it by delegated act to hold that coverage.

The definitive regime has applied since 1 January 2026, and the six-group list has been stable since the Regulation was adopted; the 2025 simplification changed the de-minimis mechanism, not the goods covered. Two moving parts still warrant a check before relying on any earlier reading. The 50-tonne threshold is expressly adjustable — set at 50 tonnes initially, but capable of being re-set by delegated act for the following calendar year if the annual review shows coverage drifting from the 99% target. And the Regulation empowers the Commission to amend the Annex I list, for instance to bring in certain slightly modified goods to counter circumvention, with a longer-term prospect of extending it to downstream products. For a compliance owner the practical consequence is that the authoritative reference is always the current consolidated Annex I on EUR-Lex, read together with the CN code in force for the year of import, rather than a static copy. The declarant registration, certificate and reporting duties that follow once an import is in scope are covered in the companion dossier on CBAM obligations for importers.

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