Core Finding

SNSUC’s core product lines are not on the CBAM list today — but carbon data demands have already arrived

CBAM entered its definitive phase on 1 January 2026, but its scope is limited to cement, iron & steel, aluminium, fertilisers, hydrogen and electricity. Paraffin wax, base oil, fuel oil, bitumen, petroleum coke and rubber are outside the list; upstream emissions from petroleum coke used as anode feedstock are also excluded from aluminium embedded emissions.

The real pressure comes from elsewhere: EU customers, driven by CSRD and their own Scope 3 targets, are requesting product carbon footprint data from suppliers. The cost of missing data is lost inquiries and disqualified tenders — not certificate fees. Building a verifiable carbon data foundation now is the right move.

Scope Determination

CBAM Scope Checker

Preliminary screening by CN code against the CBAM six-sector list.

Quick check — core product lines:
Enter a code or tap a category above to get a preliminary determination.
View CN code lists for the six covered sectors
Iron & steel
72 · 26011200 · 7301 · 7302 · 730300 · 7304 · 7305 · 7306 · 7307 · 7308 · 730900 · 7310 · 731100 · 7318 · 7326
Excludes: 72022000 · 72023000 · 72025000 · 72027000 · 72028000 · 72029100 · 72029200 · 72029300 · 720299 · 72029910 · 72029930 · 72029980 · 7204 — 7204 (ferrous scrap) is excluded.
Aluminium
7601 · 7603 · 7604 · 7605 · 7606 · 7607 · 7608 · 76090000 · 7610 · 76110000 · 7612 · 76130000 · 7614 · 7616
Excludes: 7602 · 7615 — 7602 (aluminium scrap) and 7615 (certain household articles) are excluded.
Cement
25070080 · 25231000 · 25232100 · 25232900 · 25233000 · 25239000
Fertilisers
28080000 · 2814 · 28421000 · 3102 · 3105
Excludes: 31056000 — 31056000 is excluded.
Hydrogen
28041000
Electricity
27160000

CBAM scope is defined by CN (Combined Nomenclature) code, not product description. The codes listed serve as a preliminary screening only; final classification rests with customs and trade compliance teams.

Myth vs Fact

Common Misconceptions

All exports to the EU are subject to CBAM

No. CBAM covers only cement, iron & steel, aluminium, fertilisers, hydrogen and electricity — defined by CN code, not product description. Petroleum products (paraffin wax, base oil, fuel oil, bitumen, petroleum coke) are currently outside the list.

Petroleum coke feeds aluminium anodes, so it counts in aluminium embedded emissions

No. Per CBAM Guidance 5e (14 Aug 2026), alumina, prebaked anodes, anode paste and cryolite are not treated as precursors; their upstream emissions are excluded from embedded-emissions calculations.

CBAM certificates must be purchased during 2026

No. Certificate sales open on 1 February 2027. During 2026 importers track imports by quarter (the 2026 certificate price is the ETS quarterly average of the import quarter); the first annual declaration and surrender is due 30 September 2027.

CBAM is the importer’s obligation and does not concern exporters

Incorrect. The legal obligor is the EU importer (authorised CBAM declarant), but EU guidance states importers may seek information from all parties in the supply chain. Missing emissions data can delay or block goods at the border — the exporter bears the data and commercial risk in practice.

Key Compliance Timeline

2023-10-01

CBAM transitional period begins

Past

Importers report embedded emissions quarterly (direct and indirect), with no financial obligation.

Source ↗
2025-10-17

Omnibus simplification regulation published in the Official Journal

Past

50 t/year mass threshold replaces the €150 per-consignment allowance (Regulation (EU) 2025/2083 in force from 20 Oct 2025).

Source ↗
2025-12-17

Commission proposes new Regulation strengthening CBAM

Past

Proposes extending scope to downstream goods; legislative process ongoing.

Source ↗
2025-12-31

Transitional period ends

Past

Quarterly reporting ends; the definitive regime applies from the following day.

Source ↗
2026-01-01

CBAM definitive regime begins (financial obligations accrue)

Current

CBAM goods may only be imported by an authorised CBAM declarant; the status is required above the 50 t/year threshold. CBAM factor is about 2.5% in 2026, rising to 100% by 2034.

Source ↗
2026-07-31

Default values correction Regulation (EU) 2026/1740 published

Current

Corrects selected default values, production-route indicators and product-code entries, applying retroactively from 1 Jan 2026; affected importers may need to revisit 2026 calculations.

Source ↗
2026-08-14

CBAM Guidance 5e (aluminium) published

Current

Confirms aluminium counts direct emissions only; alumina, prebaked anodes, anode paste and cryolite are not treated as precursors.

Source ↗
2027-01-01

UK CBAM commences

Upcoming

Covers aluminium, cement, fertiliser, hydrogen and iron & steel, across the whole UK including Northern Ireland.

Source ↗
2027-02-01

Sale of CBAM certificates begins

Upcoming

No certificate purchases during 2026, but imports must be tracked by quarter; the 2026 certificate price is the ETS quarterly average of the quarter of importation.

Source ↗
2027-09-30

First annual CBAM declaration and certificate surrender (covering 2026 imports)

Upcoming

Declarants report the previous year's embedded emissions and surrender matching certificates; a carbon price already paid in the country of production can be deducted.

Source ↗
2028-01-01

Proposed extension to steel- and aluminium-intensive downstream goods (subject to adoption)

Proposed

Would cover machinery, components and finished products. Organic chemicals, polymers and refined petroleum products are listed as potential directions under review.

Source ↗
2034-01-01

CBAM factor reaches 100%

Upcoming

As EU free allowances are phased out, CBAM coverage rises from about 2.5% in 2026 to full.

Source ↗

Regulation Matrix

EU Carbon Border Adjustment Mechanism (CBAM)

Definitive regime
Regulation (EU) 2023/956
Jurisdiction: 欧盟 · From 2026-01-01

Scope: Cement, iron & steel, aluminium, fertilisers, hydrogen and electricity, defined by CN code lists.

For petrochemical trade: Petroleum products (paraffin wax, base oil, fuel oil, bitumen, petroleum coke) are currently NOT on the CBAM list. The obligated party is the EU importer (authorised CBAM declarant); exporters act as data providers.

Official source ↗

CBAM Simplification Regulation (Omnibus package)

In force
Regulation (EU) 2025/2083
Jurisdiction: 欧盟 · From 2025-10-20

Scope: Replaced the €150 per-consignment allowance with a single mass-based threshold of 50 tonnes of CBAM goods per importer per year. Does not apply to hydrogen or electricity.

For petrochemical trade: The Commission estimates this exempts roughly 90% of importers while still capturing about 99% of embedded emissions — the burden sits with a small number of large importers.

Official source ↗

CBAM Methodology Regulation

In force
Regulation (EU) 2025/2547
Jurisdiction: 欧盟 · From 2026-01-01

Scope: Article 4: the functional unit defaults to 'production of goods, expressed in tonnes, falling under the same CN code'. Fertilisers by nitrogen content, cement by clinker content.

For petrochemical trade: The basis for calculation classification. Crude steel, steel products, unwrought aluminium and aluminium products must be aggregated if they differ only in dimensions/shape with identical precursors.

Official source ↗

CBAM Default Values Correction Regulation

In force (retroactive)
Regulation (EU) 2026/1740
Jurisdiction: 欧盟 · From 2026-01-01

Scope: Published 31 July 2026, correcting selected default values, production-route indicators and product-code entries, applying retroactively from 1 January 2026.

For petrochemical trade: Affected importers may need to revisit 2026 calculations. Example: default values for aluminium precursors of undetermined origin rose ~47.5% (CN 7616 99 90 from 3.770 to 5.559 tCO₂e/t).

Official source ↗

CBAM Guidance 5e: Sector-specific guidance for aluminium

Published
European Commission Guidance (5e)
Jurisdiction: 欧盟 · From 2026-08-14

Scope: Covers unwrought aluminium (CN 7601) and aluminium products (CN 7603–7616). Aluminium is on the direct-emissions-only list; indirect emissions are not reported separately in the definitive period.

For petrochemical trade: Key determination: alumina, prebaked anodes, anode paste and cryolite are NOT treated as precursors under CBAM; their upstream emissions are excluded from embedded-emissions calculations — i.e. upstream emissions from petroleum coke used as anode feedstock are not counted.

Official source ↗

CBAM Strengthening & Scope Extension Proposal

Legislative procedure ongoing
Commission proposal of 17 December 2025
Jurisdiction: 欧盟 · From 2028-01-01

Scope: Proposed extension from 1 January 2028 to steel- and aluminium-intensive downstream goods (machinery, components, finished products). Organic chemicals, polymers and refined petroleum products are listed as potential directions under review.

For petrochemical trade: Forward signal for petrochemical trade: if organic chemicals and polymers are brought in, downstream petrochemical chains are directly affected — a product carbon footprint data foundation should be built in advance.

Official source ↗

EU Emissions Trading System (EU ETS)

In force
Directive 2003/87/EC (as amended)
Jurisdiction: 欧盟 · From 2005-01-01

Scope: CBAM certificate pricing is anchored to ETS allowance auction prices: quarterly average of the quarter of importation in 2026, weekly average from 2027 onward.

For petrochemical trade: The direct determinant of carbon cost. The CBAM factor rises from about 2.5% in 2026 to 100% by 2034.

Official source ↗

UK Carbon Border Adjustment Mechanism

Commencing 2027
Finance Act 2026 + secondary regulations
Jurisdiction: 英国 · From 2027-01-01

Scope: Covers aluminium, cement, fertiliser, hydrogen, iron and steel. Imported aluminium and steel scrap are excluded. Primary legislation in Finance Act 2026; secondary legislation released for technical consultation in 2026.

For petrochemical trade: Exports to the UK require separate assessment. The UK has decided not to extend CBAM to refined oil products in January 2028, and continues to assess later feasibility.

Official source ↗

UK Treasury: refined oil products not included in CBAM for Jan 2028

Decided
HM Treasury ministerial answer (April 2026)
Jurisdiction: 英国 · From 2026-04-15

Scope: Following strategic and technical assessment, the UK Government decided not to expand CBAM to refined oil products in January 2028, and will continue working with the sector to assess the case for later expansion.

For petrochemical trade: A favourable, explicit signal for fuel oil and refined product exporters to the UK: no UK CBAM certificate cost in the near term.

Official source ↗
Regulations pending verification before inclusion
CSRDCSDDDISO 14067China PCF standardChina national carbon market

CBAM legislation is evolving (default-value corrections and scope extension proposals are in progress). Verify against the latest European Commission publications before external citation.

Carbon Data Calculation & Notarization

Verified factors & parameters

Anode consumption stoichiometric factor3.664 tCO2/tC
欧盟《CBAM 指南 5e:铝行业特定指南》(2026-08-14) ↗
CF4 slope (modern point-fed prebake)0.104 kg CF4/t Al per AE-min/cell-day
欧盟《CBAM 指南 5e:铝行业特定指南》(2026-08-14) ↗
CBAM default value annual mark-up
2026 10% · 2027 20% · 2028+ 30%
CBAM factor (phasing in as free allowances are withdrawn)
2026 ≈ 2.5% → 2034 100%
About 2.5% in 2026, rising annually to 100% by 2034. Intermediate-year values should be checked against the Commission's latest published table.
CBAM de minimis threshold
50 t / importer / year

Factors pending (needed for petrochemical PCF)

The following factors have no verified authoritative value yet, so automated PCF calculation for petrochemical lines is not offered on this page — we leave it blank rather than fill in estimates.

Grid electricity emission factor
tCO2/MWh · 需按产地电网(如中国全国或区域电网因子)填入经核验的最新官方发布值
Steam emission factor
tCO2/GJ · 需按锅炉燃料与效率填入经核验值
Natural gas combustion factor
tCO2/GJ · 需填入经核验值(IPCC 或国家指南)
Diesel combustion factor
kgCO2/L · 需填入经核验值
Sea freight emission factor
gCO2/t·km · 需按船型与载重率填入经核验值
Road freight emission factor
gCO2/t·km · 需按车型与载重率填入经核验值

Carbon data notarization (browser-side SHA-256)

Enter a carbon data summary or JSON to generate a SHA-256 fingerprint locally. The fingerprint can be attached to trade documents as proof the data was not altered. Source text never leaves your browser.

Output of this tool is an internal estimate, not verified CBAM filing data or a certified product carbon footprint. It must be validated by an accredited verifier before being used as a filing basis.

Need a carbon data plan for a specific product line?

Provide the CN code and product description; we return a scope determination, a data-gap list, and a carbon footprint accounting pathway.

Consult on Carbon Compliance →