CBAM market-share assessment depends on product-level EU import data

BRUSSELS, Oct. 22, 2026 — Global exporters are competing for European industrial orders as tariffs, volatile energy costs, weak industrial demand and the European Union’s Carbon Border Adjustment Mechanism (CBAM) reshape procurement decisions. The latest official trade releases also show why changes in headline import values cannot be linked to CBAM without detailed work by product and country of origin.

Eurostat’s Oct. 16 release, covering August 2026, reported EU imports from outside the bloc of €228.0 billion. That was up 18.2% from €192.9 billion in August 2025. The EU’s monthly external trade deficit widened to €25.2 billion, compared with €7.5 billion in August 2025.

The figures cover all merchandise imports rather than only goods subject to CBAM. Movements in energy and machinery were described as substantial contributors to the overall trade balance. As a result, the aggregate totals are not treated as evidence of changes in carbon-border-exposed import flows.

Aggregate import growth versus CBAM market shares

China supplied €53.1 billion of EU imports in August, up 19.7% year on year. Imports from Türkiye reached €7.3 billion, an increase of 0.7%, while imports from India totalled €6.0 billion, up 18.3%. These partner-level changes were presented as part of total merchandise trade.

The same dataset includes many products outside CBAM’s scope. Customs values reflect monetary value rather than physical tonnage or embedded emissions, so growth from a trading partner does not automatically translate into a larger share of a specific covered product market.

A carbon-relevant comparison therefore requires product-level customs data and consistent origin definitions. It also depends on separating goods already covered by CBAM from downstream products that have been proposed for inclusion.

CN-code selection and unit-value calculations for steel and aluminium

For covered steel products, analysts are required to aggregate the relevant eight-digit Combined Nomenclature (CN) codes listed in Annex I. The approach also calls for consistent reporting definitions and a distinction between existing covered products and proposed downstream additions.

For aluminium, unwrought metal classified under CN 7601 cannot be combined indiscriminately with fabricated products under other headings. Calculating a weighted average customs price in euros per tonne also requires comparable import values and net mass.

A robust comparison should cover the latest month, the preceding month, the corresponding month a year earlier and year-to-date figures. For each country of origin, it should report shares of extra-EU import tonnage and value, changes in those shares in percentage points, changes in tonnes and implied customs unit values.

Goods originating in Norway, Iceland, Liechtenstein and Switzerland require separate treatment because they benefit from relevant exemptions under the applicable CBAM framework. Broad Harmonized System chapter statistics can provide context but cannot replace an auditable product-level calculation.

Flat-steel import competition and limits of historical totals

Historical trade figures point to competition in Europe’s flat-steel import market. EUROFER’s European Steel in Figures 2026, using 2025 trade data, put EU imports of flat steel products at approximately 23.1 million tonnes.

Türkiye supplied 3.28 million tonnes or 14.2% of the total, while South Korea supplied 3.24 million tonnes or 14.0%. The figures were described as covering a broader group of finished flat products rather than a CN8-filtered total limited to CBAM-covered imports.

The same historical totals were also noted as not establishing market shares for October 2026. The distinction is relevant because product-group totals from earlier periods cannot be used directly to determine current competitive positions under the definitive carbon-border regime.

Steel demand signals and complications from processing chains

In its Oct. 1 market outlook, EUROFER reported that EU steel imports declined 5% in the first half of 2026 after an exceptional surge in late 2025. EUROFER also reported exports falling by 20% over the same period.

The reversal in imports may partly reflect inventory accumulation ahead of the definitive CBAM phase. It was also described as consistent with weak steel demand, trade safeguards, price movements and logistics constraints, with shipment timing and product-level evidence needed to attribute changes to any single factor.

Comparisons between countries are complicated by where processing takes place within supply chains. Steel slab imported from one country and converted into a finished product in another may acquire a different non-preferential origin than that of its precursor.

Customs unit values require similar caution because they can change due to different product grades, alloy content or delivery terms rather than shifts in underlying pricing pressure alone.

Separating customs origin from shipping routes

The distinction between customs origin and shipping route becomes important when suppliers use distribution centres within the EU or neighbouring countries. A shipment invoiced through an intermediary does not automatically take on that intermediary’s country of origin for customs purposes.

Analysts are expected to use the reported partner-origin field alongside applicable non-preferential origin rules and the relevant import regime, including any applicable exemptions. Treating a redistribution hub as the producing country can distort national market shares and lead to incorrect conclusions about which exporters gain business at others’ expense.

A reproducible assessment should document the data-extraction date, exact CN8 selection, monthly coverage, provisional-data flags and the formula used to calculate unit values. It should also treat share changes precisely—for example, moving from 10% to 12% is a gain of two percentage points rather than twenty percentage points.

Procurement factors before definitive CBAM effects are measurable

For European buyers sourcing from Serbia, Montenegro, Türkiye, India, China and Ukraine, procurement decisions increasingly combine competitive delivered prices with reliable emissions data and predictable supply conditions.

In 2026, these factors may influence purchasing choices before definitive evidence becomes available on any CBAM-driven market-share shift. Establishing competitive effects requires analysis at CN-code level with consistent treatment of physical volumes, customs values, product origin and applicable exemptions.

The latest aggregate trade figures provide context for changes in the European import market but do not establish a ranking of CBAM winners and losers based on headline movements alone.

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