CBAM: Frequently Asked Questions

CBAM: Frequently Asked Questions(1)

2025-06-10

CBAM Knowledge

Do we need to submit data if precursor materials are involved in CBAM?

Yes. If an exported product uses CBAM-covered goods as precursor materials during production, relevant data must be submitted based on importer‘s requirement. For example, a radiator manufacturer may be required by the EU importer to report emissions data related to precursor items such as screws or bolts used in production.

Are goods processed in the EU exempt from CBAM?

Generally, CBAM only applies to goods imported into and released for free circulation within the EU, and products stored under customs supervision for re-export or further processing are exempt. However, once such goods are processed and enter the EU market, even the final product is no longer classified as a CBAM good, reporting obligations may still apply if CBAM-listed materials were used.

Are small shipments exempt from CBAM?

Yes. The EU applies certain exemptions:
De minimis exemption: Single shipments valued under €150.
Military use exemption: Imports under agreements with EU military authorities.
EFTA exemption: Goods from countries participating in the EU ETS (e.g., Norway, Iceland, Liechtenstein) or with fully linked schemes (e.g., Switzerland).
Limited electricity exemption: Applies if the non-EU country is fully integrated into the EU electricity market and no CBAM-compliant methodology exists.

How to verify whether a product is covered by CBAM?

CBAM currently applies to 567 products across sectors such as aluminum, cement, electricity, fertilizers, hydrogen, and steel. To determine coverage, check the first 2–6 digits of the CN code of the export product against the EU CBAM list.

If my product’s HS code shares the first six digits with a CBAM CN code, should I report?

Yes. The HS Code (Harmonized System) is a global customs classification standard, while the CN Code is the EU’s version based on the HS Code. If the first 6 digits of the HS code match a listed CBAM CN code, reporting is required—even if the full code differs.

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