CBAM - Carbon Border Adjustment Mechanism
CBAM Compliance Statement: Precision Machined Nuts and Washers
Official Regulatory Context
This statement confirms the status of fasteners (specifically nuts and washers) manufactured by bar turning and mechanical machining under the Carbon Border Adjustment Mechanism (CBAM) per Regulation (EU) 2023/956 and Commission Implementing Regulation (EU) 2023/1773.
1. Product Scope and Material Applicability
Only goods listed in Annex I of Regulation (EU) 2023/956 are subject to CBAM. The following table identifies the status of our predominantly manufactured goods:
| MATERIAL SUBSTRATE | RELEVANT CN CODES | CBAM SCOPE | SOURCE REFERENCE |
|---|---|---|---|
| Iron and Steel | 7318 (Nuts), 7318 21 (Washers) | In Scope | Annex I, Section 5 |
| Stainless Steel | 7318 (Nuts), 7318 21 (Washers) | In Scope | Annex I, Section 5 |
| Aluminium | 7616 10 (Nuts/Washers) | In Scope | Annex I, Section 6 |
| Brass/Copper/Bronze | 7415 (Fasteners) | Out of Scope | These are not in Annex I, therefore exempt. |
| Nylon (polymers) | 3926 90 | Out of Scope | These are not in Annex I, therefore exempt. |
CN codes for CBAM-specific Material
This table provides a consolidated reference of EU CN 10‑digit codes for CBAM‑covered aluminium, stainless steel, and steel bar materials used in the manufacture of precision fasteners. Each CN code is mapped to the specific engineering grades supplied as round, square, or hexagon bars, ensuring accurate classification for CBAM reporting, customs declarations, and supply‑chain compliance.
By grouping multiple grades under each CN code, this dataset offers a fast, authoritative lookup for materials such as 230M07, 11SMnPb30, C45, 606M36T, 709M40T, 817M40T, 303, 304, 316, 6026T9, 2011T3, 6082T6, and more. All listed CN codes fall within the official CBAM scope for iron, steel, and aluminium products, making this table a reliable resource for manufacturers, importers, and compliance teams seeking correct tariff classification.
| CN CODE | MATERIALS | DESCRIPTION |
|---|---|---|
| 7604219000 | 6026T9, 2011T3, 6011, 6082T6 | Aluminium bars and rods alloyed square (other shapes) |
| 7604291000 | 6026T9, 2011T3, 6011, 6082T6 | Aluminium bars and rods alloyed round |
| 7604211000 | 6026T9, 2011T3, 6011, 6082T6 | Aluminium bars and rods alloyed hexagonal |
| 7222111100 | 303, 304, 310, 316 | Stainless steel bars and rods cold-finished round |
| 7222202000 | 303, 304, 310, 316 | Stainless steel bars and rods square |
| 7222302000 | 303, 304, 310, 316 | Stainless steel bars and rods hexagonal |
| 7215909000 | 230M07, 230M07Pb, 11SMnPb30 | Non-alloy steel bars cold-finished round |
| 7215509000 | 230M07, 230M07Pb, 11SMnPb30 | Non-alloy steel bars cold-finished square |
| 7215519000 | 230M07, 230M07Pb, 11SMnPb30 | Non-alloy steel bars cold-finished hexagonal |
| 7214999000 | 080A15, 070M20, 080A42, 080M40, C45 | Non-alloy steel bars hot-rolled round |
| 7214919000 | 080A15, 070M20, 080A42, 080M40, C45 | Non-alloy steel bars hot-rolled square |
| 7214929000 | 080A15, 070M20, 080A42, 080M40, C45 | Non-alloy steel bars hot-rolled hexagonal |
| 7228102000 | 212A42, L7/B7 | Other alloy steel bars hot-rolled round |
| 7228202000 | 212A42, L7/B7 | Other alloy steel bars hot-rolled square |
| 7228302000 | 212A42, L7/B7 | Other alloy steel bars hot-rolled hexagonal |
| 7228702000 | 605M36T, 606M36T, 709M40T, 817M40T | Other alloy steel bars cold-finished round |
| 7228502000 | 605M36T, 606M36T, 709M40T, 817M40T | Other alloy steel bars cold-finished square |
| 7228602000 | 605M36T, 606M36T, 709M40T, 817M40T | Other alloy steel bars cold-finished hexagonal |
2. System Boundaries and Excluded Processes
Per Section 2 of Annex II of Implementing Regulation (EU) 2023/1773, the "system boundary" determines reportable emissions.
- Process Definition: Our production constitutes mechanical machining of bar stock.
- Explicit Exclusions: The regulation states that the "Iron and Steel" and "Aluminium" system boundaries focus on energy intensive upstream steps. It explicitly confirms that "the following operations are not included in the system boundary: plating, cutting, welding and finishing."
- Reference: See Annex II, Section 2.1 (Iron and Steel) and Section 2.6 (Aluminium).
- Direct Emissions Status: Because our bar turning, drilling, and tapping fall within these excluded categories, our machining process does not generate reportable "direct embedded emissions."
3. Indirect Emissions (Electricity) and Data Tracking
Regulatory Basis for Exemption
The requirement to report indirect emissions (emissions from the generation of electricity consumed during production) is strictly limited to specific categories of goods. For fasteners produced under CN codes 7318 (Iron and Steel) and 7616 (Aluminium), indirect emissions are currently exempt from the CBAM reporting scope.
Direct Quote from Regulation (EU) 2023/956, Article 7(1):
"Indirect emissions shall be excluded from the scope of this Regulation for the following goods: [...] 5. Iron and steel: all goods [...] excluding those produced in installations where the production process involves a smelting or chemical reduction process [...] 6. Aluminium: all goods."
Legal Interpretation via Annex II:
When viewing Annex II (List of goods for which only direct emissions are to be taken into account), the regulation lists "Iron and steel" and "Aluminium" as categories where indirect emissions are excluded. This is because these goods (fasteners) are produced through mechanical processes rather than the high-heat chemical reduction processes used in primary smelting.
FAQ – CN Codes for CBAM‑Covered Aluminium, Stainless Steel & Steel Bars
1. What is the purpose of this CN‑code table?
This table provides the correct EU CN 10‑digit tariff codes for CBAM‑covered aluminium, stainless steel, and steel bar materials used in precision machining. It supports accurate classification for imports declared under the EU Carbon Border Adjustment Mechanism (CBAM), as required by Commission Implementing Regulation (EU) 2023/1773.
2. Why is this table important for CBAM compliance?
CBAM reporting is based entirely on the CN code of the imported product. Only CN codes listed in Annex I of Regulation (EU) 2023/956 are CBAM‑covered. All codes in this table fall within that scope. Official list: CBAM Regulation (EU) 2023/956 – Annex I.
3. How are material grades mapped to CN codes?
Grades such as 230M07, 11SMnPb30, C45, 605M36T, 606M36T, 709M40T, 817M40T, 303, 316, 6026T9, 6082T6 are mapped based on CN rules for:
- Alloy vs non‑alloy steel
- Stainless vs non‑stainless
- Aluminium alloy series
- Bar shape (round, square, hexagon)
- Finishing condition (hot‑rolled vs cold‑finished)
These rules follow the Combined Nomenclature 2024 EU CN 2024 TARIC.
4. Are all CN codes in this table officially CBAM‑covered?
Yes. Every CN code listed is included in the CBAM product scope defined in:
- Regulation (EU) 2023/956, Annex I
- Implementing Regulation (EU) 2023/1773, Annex II
These documents specify that iron, steel, and aluminium bars and rods are CBAM‑covered goods.
5. Why are aluminium grades classified as alloyed?
Grades like 6026T9, 2011T3, 6011, 6082T6 belong to the 2xxx and 6xxx aluminium series, which are classified as alloyed aluminium under CN heading 7604. Alloyed aluminium bars fall under 7604.21 (hexagon/square) and 7604.29 (round). Classification rules:
EU TARIC Consultation.
6. How do I know whether a steel grade is alloy or non‑alloy?
Non‑alloy steels (e.g., 230M07, 11SMnPb30, C45) fall under CN 7214/7215, while alloy steels (e.g., 606M36T, 709M40T, 817M40T, L7/B7) fall under CN 7228. Classification is based on chemical thresholds defined in the CN Explanatory Notes:
CN Explanatory Notes – Chapter 72.
7. Why does the finishing condition (hot‑rolled vs cold‑finished) affect the CN code?
The CN system distinguishes between hot‑rolled and cold‑finished (bright) bars because they have different production routes and mechanical properties. Cold‑finished bars fall under 7215 (non‑alloy) or 7228 50/60/70 (alloy), while hot‑rolled bars fall under 7214 or 7228 10/20/30. This distinction is required for CBAM reporting under Implementing Regulation (EU) 2023/1773.
8. Why are multiple material grades grouped under one CN code?
The CN system classifies products by chemical composition and form, not by commercial grade names. Many engineering grades share identical CN characteristics (e.g., alloy steel, cold‑finished, hexagon bar), so grouping them under one CN code improves accuracy and reduces classification errors.
9. Can this table be used for supplier declarations and CBAM reporting?
Yes. The consolidated format allows suppliers to match their material grades to the correct CBAM‑covered CN code, improving traceability and reducing errors in embedded‑emissions reporting. This supports obligations defined in Article 6 of Regulation (EU) 2023/956:
CBAM Regulation – Article 6.
10. Does the CN code affect how embedded emissions are calculated?
Yes. Under CBAM, the CN code determines which emission factors, calculation rules, and reporting templates apply. Importers must use the correct CN code to ensure their CBAM report aligns with the methodology in Annex IV of Implementing Regulation (EU) 2023/1773:
CBAM Implementing Regulation – Annex IV.
11. Why does CBAM require 10‑digit CN codes instead of 8‑digit codes?
The EU uses 10‑digit TARIC codes for customs declarations. CBAM reporting must match the exact 10‑digit code declared at import, as stated in Article 5 of Regulation (EU) 2023/956. This ensures consistency between customs data and CBAM emissions reporting.
12. What is CBAM (Carbon Border Adjustment Mechanism)?
The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation designed to prevent carbon leakage by requiring importers to report and pay for the embedded emissions of certain carbon‑intensive goods entering the EU. CBAM applies to specific CN codes listed in Annex I of Regulation (EU) 2023/956, including iron, steel, and aluminium bars.
Official regulation: Regulation (EU) 2023/956 – Establishing CBAM
13. What is EU TARIC?
TARIC (Integrated Tariff of the European Union) is the EU’s 10‑digit customs classification system used for import declarations, duty calculation, and CBAM reporting. TARIC expands the 8‑digit CN code into a 10‑digit structure used in all EU customs filings. CBAM declarations must use the exact 10‑digit TARIC code declared at import.
Official TARIC database: EU TARIC Consultation
14. What does CN (Combined Nomenclature) mean?
The Combined Nomenclature (CN) is the EU’s harmonised 8‑digit classification system for goods, forming the basis of both customs tariffs and CBAM product scope. CN codes determine whether a product is CBAM‑covered and which reporting rules apply. The CN is updated annually and published in the Official Journal of the EU.
Official CN publication: Combined Nomenclature 2024 (OJ L 202)