Trojan Special Fasteners Ltd | Specialist Nuts Fasteners | Nuts Bolts Washers | Precision Polygon Turning | Fastener Manufacturer

41. Can EU importers ask us for full lifecycle emissions for our nuts, even though nuts are CBAM-covered?
Yes. EU importers may request emissions data that goes beyond the strict CBAM embedded emissions boundary, and we can accommodate most such requests. It is also worth clarifying that our finished iron and steel nuts under CN 7318 and our aluminium fasteners under CN 7616 10 00 are already CBAM-covered goods, so EU importers have a binding obligation to report their embedded emissions, not merely a voluntary interest in doing so.

Why EU importers may request broader emissions data
Beyond their CBAM obligations, many EU companies are subject to, or preparing for, wider sustainability reporting requirements that call for more comprehensive emissions information than CBAM strictly requires. These include:

• The EU Corporate Sustainability Reporting Directive (CSRD), which requires large EU companies and some non-EU companies with EU operations to report on their value chain greenhouse gas emissions including Scope 3 upstream emissions from purchased goods and services
• The European Sustainability Reporting Standards (ESRS), which set out the detailed disclosure requirements under CSRD and include upstream Scope 3 emissions from purchased materials
• Voluntary carbon accounting and net zero commitments under which EU companies track the full embedded carbon of their supply chain
• Internal carbon pricing schemes where EU companies assess the carbon cost of their supply base in preparation for escalating CBAM certificate prices, which are projected to reach potentially EUR 150 per tonne of CO2e by 2030

What we can provide beyond strict CBAM requirements
Our CBAM embedded emissions data covers the production of our nuts as CBAM goods, including the precursor bar embedded emissions and our own direct and indirect production emissions. For customers who need broader lifecycle context, we can additionally provide:

• Bar-level embedded emissions broken down by production stage where our bar suppliers can provide that level of detail
• Our electricity consumption data per batch, which supports Scope 2 and Scope 3 upstream calculations under the GHG Protocol framework
• Material efficiency data including scrap rates, which some lifecycle assessment methodologies require
• Transport information for their own logistics emissions calculations, noting this is not part of CBAM
• Information on our bar suppliers' country of origin and production route, which supports country-level emissions benchmarking

UK CBAM relevance
The UK CBAM, which comes into force on 1 January 2027, will initially cover steel and aluminium among other sectors. Indirect emissions are expected to be excluded from the UK CBAM scope initially, unlike the EU version. However, the UK CBAM framework may evolve, and our existing monitoring systems already capture the data that would be required for any future expansion.

Important framing
We should be clear with EU customers about what data is being provided in each context: what forms part of our CBAM-compliant embedded emissions submission, and what is being provided additionally for their broader sustainability reporting. Conflating the two could create confusion about what our CBAM obligations are and what is voluntary supplementary information.

Source: Regulation 2023/956

42. If a distributor mixes our nuts with nuts from other manufacturers, can we still provide emissions data?
Yes, but only for our nuts. We can provide precise, batch-traceable CBAM-compliant emissions data for every nut we manufacture and supply. The responsibility for managing mixed batches and maintaining the traceability required for CBAM declarations rests with the distributor and ultimately with the EU importer as the CBAM declarant.

What we provide
Our data covers the nuts we produce and supply. For each batch we can provide:

• The CN code of the nuts (for example CN 7318 16 for carbon steel nuts, CN 7318 12 10 or CN 7318 14 10 for stainless steel nuts, CN 7616 10 00 for aluminium nuts)
• Specific direct and indirect embedded emissions per tonne for our nuts, calculated from our precursor bar data and our own production process energy consumption
• The batch reference and quantity supplied, allowing our data to be matched to specific delivery records
• The bar precursor data supporting the emissions calculation, including CN code, country of origin, supplier and embedded emissions per tonne of bar

The mixed batch problem
When a distributor holds stock from multiple suppliers and despatches mixed consignments to EU customers, the EU importer faces a traceability challenge. CBAM requires that the embedded emissions declared correspond to the actual goods imported. If the consignment contains nuts from several manufacturers, the importer must either:

• Maintain strict lot segregation and declare separately for each manufacturer's goods, using each manufacturer's actual emissions data
• Apply a weighted average of the embedded emissions of the constituent lots, documented with reference to each supplier's data
• Fall back to the official CN 7318 default values for the whole consignment, which avoids the traceability problem but may result in higher declared emissions than actual, increasing CBAM certificate costs

Our batch-level traceability is designed to support the first of these approaches. Each batch we despatch carries a unique batch reference that links to our internal records, our bar supplier's material certificate and our emissions data for that production run. This gives distributors the granular data they need to maintain segregated CBAM records if they choose to do so.

Our position on distributor responsibilities
We cannot provide emissions data for nuts made by other manufacturers, and we cannot be responsible for emissions figures applied to mixed consignments where our nuts have been combined with others. We can, and should, provide clear and complete batch-level documentation for every delivery we make, so that distributors have the information needed to maintain proper segregation.

Source: Regulation 2023/956

43. If our bar supplier changes their production route, does this affect the emissions data we provide?
Yes. Changes in bar production route can significantly change the embedded emissions of the bar we use as precursor material, and therefore the embedded emissions of the finished nuts we report to our EU customers. We treat production route changes by bar suppliers as a material data event requiring an update to our CBAM reporting.

What constitutes a production route change
Production route changes that affect embedded emissions include:

• A change in steelmaking process, for example from basic oxygen furnace to electric arc furnace, or vice versa. EAF steelmaking using a high proportion of recycled scrap typically produces significantly lower direct emissions than BOF steelmaking from primary iron
• A change in the proportion of recycled scrap used, even within the same furnace type
• A change from hot-rolled to cold-finished bar, or vice versa, which changes the CN code and may change the embedded emissions figure
• A change in the heat treatment condition of the bar as supplied (for example, a supplier moving from supplying annealed bar to supplying quenched and tempered bar)
• A significant change in the energy mix used at the steel mill, for example a shift to renewable electricity for EAF operations, which would reduce indirect embedded emissions
• A change in the country of production, which affects the applicable national electricity grid emission factor used for indirect emissions

Why we must track and update this
The CBAM methodology requires that embedded emissions reflect the actual production processes of the imported goods. If we continue to report embedded emissions based on an old production route after our bar supplier has changed their process, our data will no longer accurately represent the goods being supplied and could result in our EU customers under-declaring or over-declaring embedded emissions in their CBAM declarations. Either outcome creates compliance risk for them.

How we manage this in practice

• We request updated emissions data from our bar suppliers whenever we receive notification of a production route change or whenever mill certificates indicate a change in the production conditions of the bar
• We update our internal records and the precursor section of our in-house CBAM reporting template to reflect the new data
• We notify EU customers who hold our current CBAM data that an update is available, so they can revise their declarations if necessary
• Where a supplier changes production route part-way through a reporting year, we maintain separate records for bar received under the old and new route, to allow accurate per-batch reporting

Using default values after a route change
If our bar supplier is unable to provide updated actual emissions data following a production route change, we may need to reassess which official default value is most appropriate. For example, if a supplier moves from hot-rolled to cold-finished bar, we must switch from the default for the hot-rolled CN code to the default for the cold-finished CN code. If the change involves a shift to a significantly different steelmaking route, we may need to consider whether the global default still represents a reasonable estimate or whether it materially over- or understates the actual emissions.

Source: Implementing Regulation 2023/1773 Annex IV

44. Do we need to provide emissions data for scrap or waste generated during nut manufacturing?
No. Machining swarf, off-cuts and other manufacturing waste generated at our facility are not separately reportable under CBAM. However, there is an important distinction between the waste itself and the material efficiency of our production process, which does have an indirect bearing on our reported embedded emissions.

Why scrap and waste are not separately reportable
The CBAM embedded emissions methodology for iron and steel products focuses on the embedded carbon of the goods produced and sold, not on the waste generated in making them. Scrap and waste do not leave our facility as CBAM goods for import into the EU. They are either returned to the steel supply chain as recycled material or disposed of as waste, neither of which is a CBAM-relevant event at our end.

The electricity and other energy consumed in the machining operations that generate swarf is already captured in our indirect embedded emissions calculation as part of our total production electricity consumption. The energy used to produce the swarf is proportionally allocated across the finished nuts we produce via our per-tonne electricity consumption figure.

Material efficiency and its effect on embedded emissions
There is an indirect relationship between our material efficiency and our reported embedded emissions per tonne of finished nuts. Our embedded emissions calculation for the precursor bar contribution is based on the quantity of bar consumed per tonne of finished nuts, not just the weight of the finished nuts themselves. If our machining process removes a significant proportion of the bar as swarf, the embedded emissions of the full quantity of bar consumed must be attributed to the finished nuts produced, making the per-tonne embedded emissions figure higher than it would be for a more material-efficient process.

In practice, our bar consumption per tonne of finished nuts is a monitored figure in our production records, and it feeds directly into the precursor embedded emissions calculation in our in-house CBAM reporting template.

Data we can provide on request
If customers request material efficiency information for their own sustainability or lifecycle assessment reporting, we can provide:

• Average material utilisation rate per product type (finished nut weight as a proportion of bar consumed)
• Scrap generation rates per batch
• Information on how scrap is disposed of or recycled

This data is not part of our CBAM reporting but may be useful for customers' broader Scope 3 or lifecycle assessment work.

Source: Implementing Regulation 2023/1773 Annex IV

45. Do we need to provide emissions data for packaging used with our nuts?
No. Packaging materials and their associated emissions are not included in CBAM embedded emissions at any stage of the supply chain.

The CBAM Regulation applies only to the goods listed in Annex I. Packaging materials such as cardboard boxes, polythene bags, pallet wrap and wooden pallets are not CBAM goods and do not carry CBAM-reportable embedded emissions. The CBAM Questions and Answers document published by the European Commission explicitly confirms that CBAM does not apply to packaging.

The embedded emissions boundary under Article 3(22) of the CBAM Regulation covers only the production of the imported good itself, up to the point of import into the EU. Packaging applied after production at our facility is outside that boundary, and packaging applied by a distributor or freight forwarder is further outside it still.

What this means in practice

• The cardboard boxes, plastic bags or bulk containers in which we despatch our nuts do not carry any CBAM-reportable emissions
• We do not need to calculate or report the embedded carbon of our packaging materials
• The weight of packaging is not included in the net weight of CBAM goods for the purposes of the embedded emissions calculation, which uses net weight of goods only

What we can provide for wider sustainability reporting
Some EU customers operating under CSRD or voluntary sustainability commitments may request packaging information as part of their upstream Scope 3 assessment. We can assist with:

• Details of packaging types used per product category
• Approximate packaging weight per standard consignment
• Information on whether packaging is recyclable or contains recycled content
• Any packaging reduction initiatives we have underway

This is provided as supplementary sustainability information and is entirely separate from our CBAM data obligations.

Source: Regulation 2023/956

46. If EU importers request CBAM emissions data for our nuts, what do we provide?
We provide full CBAM-compliant embedded emissions data for our finished nuts as CBAM goods, using our own in-house CBAM reporting template. This is not a situation where we need to explain that nuts fall outside CBAM scope, because they do not. Our finished iron and steel nuts under CN 7318 and our aluminium fasteners under CN 7616 10 00 are CBAM-covered goods, and EU importers who import them have binding CBAM obligations.

The standard data we provide
When an EU importer requests CBAM data for our nuts, we provide via our in-house CBAM reporting template:

• The CN code of the nuts supplied
• Our specific direct embedded emissions per tonne, covering the fuel combustion emissions from our heat treatment sub-contractor's production process as the direct emissions component of our production
• Our specific indirect embedded emissions per tonne, based on our total electricity consumption across our production process and the UK national grid emission factor
• Our precursor bar data, covering the bar CN code, country of origin, supplier and specific embedded emissions per tonne
• Our installation details as the operator
• The reporting period to which the data applies
• Confirmation that no carbon price has been paid in the UK in connection with the production of these goods that would qualify for deduction under CBAM (noting this will change when the UK CBAM comes into force in 2027)

Default values versus actual data
From 1 January 2026, the definitive phase of CBAM requires EU importers to report actual embedded emissions. The official CN 7318 16 default values are 1.89 tCO2e per tonne direct and 0.32 tCO2e per tonne indirect, totalling 2.21 tCO2e per tonne. For stainless steel fasteners under CN 7318 12 10 and CN 7318 14 10, the defaults are 2.10 tCO2e per tonne direct and 1.99 tCO2e per tonne indirect, totalling 4.10 tCO2e per tonne. These defaults remain available for minor contributions below 20% of total embedded emissions, but actual data is required for the main body of the declaration.

Where our actual embedded emissions are below the relevant default, providing actual data is commercially advantageous to our EU customers as it reduces the number of CBAM certificates they must surrender and therefore their CBAM certificate cost.

Verification
From 2026, CBAM declarations based on actual values are subject to verification by accredited independent verifiers. The data we provide in our in-house CBAM reporting template must be supportable by our underlying production records, including electricity metering data, heat treatment sub-contractor invoices and fuel consumption records, and bar supplier material certificates and emissions data.

Source: Regulation 2023/956 and Implementing Regulation 2023/1773

47. Can we provide emissions data for nuts manufactured several years ago?
Yes, provided we still hold the traceability and supplier documentation for the relevant bar and nut batches. Our record-keeping obligations under CBAM and our existing quality management systems mean we should be able to reconstruct emissions data for historical batches within the retention period.

Why historical data may be requested
EU importers may need historical emissions data in several circumstances:

• They imported our nuts before they had established their CBAM data collection process and need to retrospectively populate their CBAM declarations
• They are subject to a review or correction procedure initiated by their National Competent Authority and need to provide supporting evidence for past declarations
• They are conducting a sustainability audit or lifecycle assessment covering historical purchases
• They are benchmarking their embedded emissions performance over time

What our records allow us to reconstruct
The Implementing Regulation requires records relevant to CBAM to be retained for at least four years after the relevant reporting period. Our quality management system independently requires retention of EN 10204 material certificates and batch records. For historical batches within the retention window, we can typically provide:

• The bar grade, CN code, supplier and country of origin for the bar used in a specific nut batch
• The embedded emissions of that bar, either from the original supplier data or from the official default values applicable at the time
• Our electricity consumption per tonne for the relevant production period
• Heat treatment sub-contractor records for the relevant period, if applicable
• The batch reference and production dates, allowing the data to be matched to specific delivery records and EU customs entries

Limitations
For batches produced before we implemented our current CBAM monitoring systems, we may not hold granular per-batch electricity consumption data. In those cases we can provide annual average electricity consumption figures for the production period, which is an acceptable basis for the precursor and indirect emissions calculation. We cannot fabricate data we do not hold, and where records genuinely do not exist we will say so clearly, as transparency is required under the CBAM accountability framework.

Source: Implementing Regulation 2023/1773

48. If a bar supplier provides only partial emissions data, can we still support EU importers?
Yes. We can support EU importers even when bar supplier data is incomplete, using a combination of the partial data available, official default values and our own production data. The key is being transparent about which elements of the reported embedded emissions are based on actual data and which are based on estimates or defaults.

How partial data situations arise
Bar suppliers may provide partial data in several ways:

• They provide direct emissions data but not indirect emissions data, or vice versa
• They provide emissions data for some grades or production routes but not others
• They provide data for some reporting periods but not for the current period
• They provide a single figure covering both direct and indirect but not broken down separately as CBAM requires
• They provide qualitative production route information (for example confirming EAF steelmaking) but no quantified emissions figure

How we handle each situation
Missing indirect emissions only: We can apply the official default indirect emission factor for the applicable bar CN code to our bar supplier's actual direct emissions figure. This gives a hybrid figure that is partially based on actual data.

Missing direct emissions only: We can apply the official default direct emissions value for the bar CN code alongside any indirect data the supplier provides.

Entirely missing supplier data: We apply the full official default values for the appropriate bar CN code. For our most commonly used bar types these are documented in question 36.

Partial period data: Where supplier data exists for some of the reporting year but not all, we use actual data for the covered period and default values for the uncovered period, provided the default-based portion remains within the 20% threshold for estimated values in complex goods.

The 20% threshold
The CBAM rules permit estimated values (including defaults) to be used for contributions that represent less than 20% of the total embedded emissions of the finished goods. For our nuts, the bar precursor contribution is typically the dominant element of total embedded emissions, far exceeding 20%. This means that we should make every reasonable effort to obtain actual bar data rather than relying on defaults, as using defaults for the bar precursor element will likely push us above the 20% threshold and render the CBAM report technically incomplete for the definitive period from 2026 onwards.

Documentation we provide regardless of data completeness

• Supplier name and country of origin
• Bar grade and CN code
• Production route information drawn from mill certificates or supplier declarations
• A clear statement identifying which elements use actual data and which use defaults or estimates
• Supporting documentation for the actual data elements we do hold

Source: Implementing Regulation 2023/1773

49. Do we need to provide emissions data for heat treatment of our nuts?
Yes. Heat treatment of our finished nuts is part of our production process as the operator of a CBAM installation producing CN 7318 goods, and the emissions arising from it must be included in the embedded emissions data we provide to our EU customers. This applies even though the heat treatment is sub-contracted to a third party rather than performed at our own facility.

This question is addressed in detail in question 16, which explains the full treatment of sub-contracted heat treatment in our CBAM reporting. The key points are as follows.

Direct emissions from heat treatment
Our heat treatment sub-contractor uses fuel-fired furnaces. The CO2 produced by combustion of that fuel is a direct emission of our production process for CN 7318 nuts. We must obtain fuel consumption data per tonne of nuts treated from our sub-contractor and include the resulting direct emissions in our in-house CBAM reporting template. This data forms part of the specific direct embedded emissions per tonne that we report to EU customers.

Indirect emissions from heat treatment
Our heat treatment sub-contractor also consumes electricity in operating their furnaces, handling equipment and controls. That electricity consumption per tonne of nuts treated must be included in our total electricity consumption figure for the production process, and the resulting indirect emissions must be included in our specific indirect embedded emissions per tonne.

Why sub-contracting does not remove the obligation
The CBAM Regulation defines an operator as any person who operates or controls an installation in a third country. We control the production of our nuts end to end, including the specification and commissioning of heat treatment from our sub-contractor. The emissions from that sub-contracted process are our production process emissions for CBAM purposes, not the sub-contractor's independent emissions. We are responsible for obtaining the data from them and including it in our reporting.

Using default values
If we provide the CN 7318 16 default values to EU customers (1.89 tCO2e per tonne direct, 0.32 tCO2e per tonne indirect, total 2.21 tCO2e per tonne) rather than actual data, those defaults implicitly represent a typical production process including heat treatment. In that scenario we do not need to separately account for heat treatment emissions, as the default already covers them. However, actual data is required from 2026 onwards and will likely be more commercially favourable to our EU customers if our actual emissions are below the default.

Source: Regulation 2023/956 and Implementing Regulation 2023/1773

50. What documentation can we provide to demonstrate our CBAM compliance and readiness?
We can provide a comprehensive documentation pack showing that we are operating as a fully compliant CBAM operator for our CN 7318 and CN 7616 10 00 goods, and that our systems and records meet the standards required by the CBAM Regulation and Implementing Regulation for the definitive period from 2026 onwards.

Core CBAM compliance documentation

• Our in-house CBAM reporting template, completed with specific direct and indirect embedded emissions per tonne for each CN code we produce, for the relevant reporting period
• The precursor data underlying our calculation, including bar CN codes, countries of origin, supplier names and specific embedded emissions per tonne of bar
• Our electricity consumption records per production batch, supporting our indirect emissions calculation
• The electricity emission factor used, with reference to the UK national grid emission factor source
• Heat treatment sub-contractor emissions data covering fuel consumption and electricity consumption per tonne of nuts processed
• Batch traceability records linking incoming bar deliveries to finished nut production runs and outgoing despatch records

Supporting quality and traceability documentation

• EN 10204 material certificates for bar stock, providing independent third-party verification of bar grade, chemical composition and mechanical properties
• Bar supplier country of origin declarations where available
• Internal works order and batch records
• Heat treatment sub-contractor process records and certificates

Documentation demonstrating readiness for verification
From 2026, CBAM declarations based on actual values are subject to verification by accredited independent verifiers appointed by EU importers. The documentation we hold must be sufficient to support verification of the figures we have provided. Specifically:

• Our electricity metering data must support the specific electricity consumption figure we report
• Our heat treatment sub-contractor records must support the direct and indirect emissions from that process step
• Our bar purchase records and material certificates must support the precursor embedded emissions figures we use
• Our batch records must support the link between specific bar deliveries and specific nut consignments despatched to EU customers

Alignment with regulatory requirements
Our documentation practices align with the transparency principle in Annex III Section A.2 of Implementing Regulation (EU) 2023/1773, which requires complete and transparent records to be kept at the installation for all data relevant to determining embedded emissions, including supporting documents, for at least four years after the relevant reporting period.

Bar CN codes for which we hold or can obtain emissions data

• CN 7213 and CN 7214 and CN 7215 (non-alloy steel bars)
• CN 7222 (stainless steel bars)
• CN 7228 (alloy steel bars)
• CN 7604 (aluminium bars and profiles)

Finished goods CN codes for which we report embedded emissions

• CN 7318 16 (Nuts, iron and steel)
• CN 7318 12 10 and CN 7318 14 10 (Stainless steel fasteners)
• CN 7616 10 00 (Aluminium nuts and fasteners)

Source: Regulation 2023/956 and Implementing Regulation 2023/1773