Not every product containing steel or aluminium falls within CBAM's scope. Businesses need to compare the CN code and goods description with the list in the CBAM rules, then check the conditions of application and exemptions.
This article provides a step-by-step guide, with examples and a way to record findings for discussion and confirmation with EU customers.
- Check both the CN code and the goods description. A commercial name, or the fact that a product contains steel or aluminium, is not enough to determine whether CBAM applies.
- Read the full scope of each listed code. Check the heading, exclusions and the “ex” prefix, which indicates that only some goods under that code fall within scope.
- Checking the list and checking exemptions are separate steps. For iron and steel, aluminium, cement and fertilisers, the 50-tonne threshold is aggregated per importer over a calendar year across all suppliers. It does not apply to electricity or hydrogen.
COMMODITY CODESHow do CN codes differ from HS and TARIC codes?
CN (Combined Nomenclature) is the EU's goods nomenclature, based on the Harmonized Commodity Description and Coding System (HS). CN codes are used in customs declarations and to determine the EU measures applicable to goods, including CBAM.
HS — 6 digits
An HS subheading code has six digits and is used in international goods classification. It provides an initial basis for identifying the product category, but checking the HS code alone is not always enough to determine CBAM scope.
CN — 8 digits
A CN code consists of six HS digits and two additional EU digits for more detailed classification. Businesses need to identify the correct CN code and corresponding goods description to check against the CBAM list.
TARIC — 10 digits
A TARIC code consists of eight CN digits and two additional digits for the detailed application of EU measures. The TARIC database provides information on duties and related import requirements by commodity code, country of origin and applicable date.
An eight-digit commodity code used in Vietnam does not necessarily match the EU's eight-digit CN code. Both systems are based on the six-digit HS, but their final two-digit subdivisions may differ. Businesses should therefore work with the importer to identify the appropriate CN code, rather than copying the code used in Vietnam.
Use the CN nomenclature in force at the time of importation. It is updated annually. For goods imported into the EU in 2026, businesses need to consult the version applicable to 2026 and check relevant amendments.
See the European Commission's CN overview and announcement on the 2026 CN nomenclature for further information.
PREPARATIONWhat information should you prepare before looking up a commodity code?
Correct classification requires a clear understanding of the product's actual characteristics. Generic names such as “steel fittings”, “aluminium profiles” or “construction materials” are often insufficient. Businesses should prepare a product information file covering:
- Product names and internal codes: Vietnamese name, English name used in transactions, product code, photographs or technical drawings.
- Materials and composition: Material, metal or alloy type; constituent proportions or chemical composition where needed for classification.
- Shape, dimensions and processing: Whether the product is a bar, sheet, tube, structure or assembled component; its main dimensions and the processing steps performed.
- Use and condition on importation: The product's purpose; whether imported separately, as a set or with equipment; and whether assembled or disassembled.
- Production and transaction information: Production installation, expected country of origin, EU importer, previously used commodity codes and expected import date.
Products with the same commercial name may still fall under different codes. If materials, dimensions, construction or the extent of processing differ, each type should be reviewed separately. Do not use one code for an entire product range simply because the products serve the same purpose.
LOOKUPFive steps to check CBAM scope using a CN code
- Identify the proposed CN code
Compare the product's technical records with the CN nomenclature, notes and classification rules. If a code has been used previously, check that it still matches the product's characteristics and the current nomenclature.
- Consult the EU's official system
Open TARIC Consultation, then search by commodity code or navigate through the headings to the appropriate classification level. Select the date corresponding to importation and the country of origin. Read the full descriptions, notes and relevant conditions; save the eight-digit CN code and the lookup results.
- Check Annex I to the CBAM Regulation
Check the commodity code against Annex I to Regulation (EU) 2023/956, as amended. In addition to the eight-digit code, check the chapter, heading or subheading containing it, together with exclusions and the “ex” prefix. Annex I may list codes at a broader level, so not finding the exact eight-digit code is insufficient to conclude that a product is outside the list.
- Check conditions and exemptions
After checking the list, examine the country of origin, customs procedure, importer and relevant exemption conditions. Distinguish a product outside the CBAM list from a listed product whose transaction qualifies for an exemption.
- Record the findings and confirm them with your EU partner
Record the CN code, goods description, references used, applicable conditions or exemptions, review date and unresolved issues. Send the file to the importer or customs representative for review and agreement before the declaration is made.
Do not draw conclusions from the product name alone. Keyword searches can guide the lookup, but conclusions must be based on correct classification and the scope described in the rules. The list of default emissions values does not replace Annex I to the CBAM Regulation when determining which goods are covered.
CROSS-CHECKINGHow to read commodity codes, exclusions and the “ex” prefix
Annex I lists goods at different levels: chapters, headings, subheadings or eight-digit CN codes. Businesses therefore need to check the parent codes and accompanying descriptions, rather than searching only for the product's exact eight-digit code.
Heading 7318 is included in the CBAM list and covers screws, bolts, nuts and certain similar articles of iron or steel. If a product is correctly classified under a CN code within this heading, it is covered even if Annex I does not separately list that eight-digit code.
Code 7604 21 00 covers hollow profiles of aluminium alloys and falls under heading 7604 in the CBAM list. However, not every product commercially described as an “aluminium profile” uses this code. Businesses need to check the material, shape and extent of processing at the time of importation to determine the appropriate code.
In Annex I, chapter 72 — Iron and steel includes exclusions listed after the word “Except”, meaning “excluding”. These include heading 7204, which covers ferrous waste and scrap and certain related goods.
Where the prefix “ex” appears before a commodity code, the scope covers only the goods matching the accompanying description.
For example, the entry ex 2507 00 80 covers other kaolinic clays, excluding non-calcined kaolinic clays. Businesses need to check both the commodity code and whether the product has been calcined; not all goods under code 2507 00 80 can be assumed to fall within CBAM. The scope of this entry was amended by Regulation (EU) 2025/2083.
These examples illustrate how to read Annex I to the amended CBAM Regulation; they do not replace the classification of a specific product. The descriptions are paraphrased for clarity; when determining scope, businesses need to check the full commodity codes, descriptions and exclusions in the legislation.
CONDITIONSAre all listed goods subject to CBAM obligations?
After confirming that a product is listed in Annex I, businesses need to check its origin, import quantity and customs procedure to determine the CBAM obligations for the transaction.
Origin of the goods
CBAM determines origin under the EU's non-preferential rules of origin. The country of origin is not necessarily the country of dispatch or the seller's country of establishment. See the EU rules of origin.
Mass threshold: calculated per importer
For the four groups of iron and steel, aluminium, cement and fertilisers, an importer is exempt from CBAM obligations under the mass threshold if the total net mass of goods counted towards the threshold does not exceed 50 tonnes in a calendar year.
The mass is aggregated for each importer across all four groups, shipments and suppliers. It is not a separate threshold for each group, shipment or supplier. The threshold does not apply to electricity or hydrogen.
If the threshold is exceeded, CBAM obligations apply to all relevant goods imported during the year, including goods imported before the threshold was crossed. Vietnamese businesses should therefore confirm the exemption's applicability with the importer, rather than relying solely on the quantity sold to that customer. See the Finnish Customs guidance on CBAM.
Customs procedures and inward processing
Businesses need to establish whether the goods are being released for free circulation in the EU or placed under another customs procedure.
For example, listed CBAM goods may enter the EU under a procedure for processing within the EU (inward processing), after which the processed products are released for free circulation. In this case, the declaration obligations may include the embedded emissions of the CBAM input goods, even if the processed products are not listed in Annex I.
The importer or customs representative should check the specific requirements under Article 6(3) of the CBAM Regulation.
Make the distinction: “A product outside the CBAM list” and “a listed product exempt under the applicable conditions” are different conclusions. When applying an exemption, retain the supporting basis and monitor the situation for reassessment if import quantities or conditions change.
PRACTICAL EXAMPLEExample: an exporter of aluminium profiles
Suppose business A manufactures in Vietnam and exports hollow profiles of aluminium alloys. Based on technical records and checks with the importer, the appropriate CN code is identified as 7604 21 00. The goods originate in Vietnam and are released for free circulation in the EU.
- Check the CN code against the CBAM list
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Code 7604 21 00 falls under heading 7604 listed in Annex I. The product is therefore included in the CBAM list.
- Quantity supplied by business A
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In one calendar year, business A supplies this importer with 10 tonnes of the product described above. This quantity alone is insufficient to conclude that the importer is exempt from CBAM obligations.
- Quantities from other suppliers
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In the same year, the importer purchases a further 45 tonnes of goods counted towards the CBAM threshold from other suppliers. These goods fall within one or more of the four groups: iron and steel, aluminium, cement and fertilisers.
- Exemption threshold result
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The importer's total net mass counted towards the threshold is:
10 + 45 = 55 tonnes
This exceeds the threshold of 50 tonnes per year. Assuming no other exemption applies, CBAM obligations cover all 55 tonnes, including the 10 tonnes supplied by business A, not just the 5 tonnes above the threshold.
Key point: The exemption threshold is based on each importer's total annual imports counted towards the threshold, not on quantities from each supplier separately.
Confirm the commodity code and retain the review findings
A review that records the code, the basis for classification and supporting evidence helps businesses agree requirements with EU customers and prepare suitable data.
- If the CN code has not been agreed: Provide additional technical records and ask the importer or customs representative to explain the classification basis. Mark the status as “Further confirmation needed” and record the missing information, responsible person and deadline. Do not choose a code simply because it falls outside the CBAM list.
- Keep records for each product and transaction: Record the internal code, product name, production installation, technical records, CN code and, where needed, TARIC code; the description and classification basis; the corresponding Annex I entry, exclusions or “ex” limitations; origin, customs procedure and importer. Also retain the conclusion, evidence, confirmation exchanges, review date, reviewer and date for reassessment.
- State the conclusion clearly and keep it updated: Distinguish “Listed, obligations apply”, “Not listed”, “Listed but exempt” and “Insufficient basis to conclude”. Record the supporting basis or conditions; reassess when the product, origin, customer, quantity, import procedure or rules change. If obligations apply, agree data requirements with the EU customer.
If a binding classification decision is needed: The importer may request a BTI (Binding Tariff Information) decision from an EU customs authority. It is generally valid for three years and binds EU customs authorities and the decision holder. You can consult the EBTI database, but a decision issued to another party does not automatically bind the customs treatment of your transaction.
BTI addresses tariff classification; origin, the mass threshold and CBAM conditions must still be checked separately. An emissions verification report does not replace a customs classification decision.
For products outside the CBAM list, customers may still request emissions data for supply chain management. Businesses should discuss this requirement separately.
Learn about the next steps in preparing data on the GIC Vietnam CBAM Embedded Emissions Verification page.
Updated as of 7 September 2026. This article focuses on the definitive period, based on Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, together with the 2026 CN nomenclature and the relevant legislation and guidance.
