A reliable assessment of European Union imports covered by the Carbon Border Adjustment Mechanism (CBAM) requires analysis at the eight-digit Combined Nomenclature (CN) level. The 2025 import aggregate for goods listed in Annex I of the CBAM Regulation was €111.23 billion, but broad customs chapters can include products outside CBAM coverage.
Counting every product in a chapter as exposed to a carbon-border charge can therefore misstate affected trade. Rankings also need consistent geography, year, trade flow and classification; figures for different codes or markets cannot be compared as if they described the same imports.
The largest structural categories include iron and steel products, primary aluminium, semi-finished metal products, electricity, fertilisers and clinker. Yet values vary within these groups, and the scope of a product-level assessment matters.
EU extra-EU imports of unwrought non-alloyed aluminium under CN code 7601 10 90 were about €7.51 billion in 2025. A reported value for a specific flow of hot-rolled steel from Türkiye, by contrast, cannot be treated as the EU-wide total for that customs code.
Product codes shape CBAM assessments
Primary metal, billets, sheets, tubes, profiles and fasteners can have different embedded-emissions boundaries and process requirements. For fertilisers, distinguishing urea from other nitrogen products affects which processes and precursors need to be assessed.
Electricity is classified under CN 2716 00 00 and requires a separate evidence chain involving grid scheduling, metering and emission factors, as well as direct power-purchase contracts where applicable. Electricity and hydrogen do not receive the 50-tonne annual de minimis exemption that applies to the four mass-based sectors; product classification can determine whether an importer crosses that threshold.
Companies need to reconcile product master data and customs declarations with CBAM records before calculating emissions or certificates. Incorrect coding can create liability, delay release for free circulation or distort management forecasts.
A complete CN8 intelligence table should include product descriptions, annual and quarterly values, net mass, non-EU origin, the reporting EU member state, named installations where known, main industrial processors and downstream end uses. It should also flag exempt origins and pending legislative amendments. Importer and final-beneficiary rankings based only on aggregated customs figures remain provisional; a product-level table is the foundation for meaningful rankings.