The European Commission has published the EU’s 2027 Combined Nomenclature, adding customs classifications for selected steel structures, aluminium scrap and industrial components from 1 January 2027. The revision does not itself expand the legal scope of the Carbon Border Adjustment Mechanism (CBAM), but requires exporters and customers to distinguish products already covered from those exposed only to a proposed extension.
Published on 30 October under Commission Implementing Regulation (EU) 2026/2163, the revised nomenclature will be binding for customs classification from that date. The EU’s eight-digit Combined Nomenclature supports customs declarations, applicable tariff measures and detailed international trade statistics.
New classifications for metals and components
One new code, 7308 90 53, identifies tubular steel monopile foundations and sections used in wind turbines. It falls within heading 7308, which is already relevant to the EU’s CBAM coverage of iron and steel articles, and distinguishes monopiles from other steel structures in customs records and trade statistics.
The revision also introduces new codes for aluminium waste and scrap under heading 7602. They include 7602 00 20 for production waste and scrap, 7602 00 30 for used beverage cans and 7602 00 40 for used wheels. Other classifications distinguish scrap by physical or chemical characteristics, including aluminium and silicon content, adding statistical detail to a material stream important to EU low-carbon metals supply chains. The new codes do not make aluminium scrap automatically subject to CBAM certificate obligations.
A separate iron-and-steel code, 7204 41 11, identifies certain ferrous waste containing a combined weight of at least 5% neodymium or praseodymium. That classification gives customs records more detail on scrap containing rare-earth materials, but does not establish its carbon-border treatment.
Code 8503 00 30 separately identifies wind-turbine nacelle assemblies. The classification is relevant to supply-chain monitoring, but does not automatically include nacelles in the currently adopted CBAM product list.
CBAM expansion remains under negotiation
The customs update comes as the EU separately negotiates a proposal to extend CBAM to selected downstream steel and aluminium products. Legislative proposal COM(2025)989, under procedure 2025/0419(COD), envisages expanding coverage from 2028 and introducing additional anti-circumvention measures. It has not become final law.
The European Parliament adopted amendments to the proposed expansion on 15 September 2026. Eventual product coverage must be assessed against the adopted text, rather than the Commission’s original proposal alone. The 2027 customs classifications do not decide which additional products may ultimately be covered.
Steel fabricators exporting foundations and heavy structural components from outside the EU must review customs documentation, product descriptions and embedded-emissions records. Exporters and suppliers in Serbia, Montenegro, Bosnia and Herzegovina and Türkiye, along with other European industrial-supplier countries, need to reconcile their product codes with European customers’ classifications and distinguish goods already covered by CBAM from those potentially affected only by the proposed expansion.
Steel-structure manufacturers, aluminium recyclers, industrial subcontractors and renewable-energy component suppliers may face additional documentation requirements even where their underlying emissions calculations do not change. The customs revision does not create a new carbon charge, but has practical implications for precursor accounting and monitoring imports from third countries.
Companies comparing import volumes, values or supplier-country market shares across years must use the official correlation between the 2026 and 2027 classifications. When an existing CN8 category is divided into new codes, apparent growth or decline in individual categories may reflect reclassification rather than a change in physical trade.
Banks financing industrial exporters should review whether customer contracts, customs documentation and CBAM exposure models identify the same products consistently. The immediate concern is inconsistent classification, unreliable trade comparisons and incorrect assessments of current or future CBAM obligations, while proposed additional obligations remain subject to the legislative process.