BRUSSELS, Oct. 22, 2026 – Global exporters are competing for European industrial orders as tariffs, volatile energy costs, weak industrial demand and the European Union’s Carbon Border Adjustment Mechanism (CBAM) reshape procurement decisions. However, the latest official trade figures illustrate why changes in headline import values cannot be attributed to CBAM without detailed analysis by product and country of origin.
Eurostat’s Oct. 16 release, covering August 2026, reported EU imports from outside the bloc of €228.0 billion, an increase of 18.2% from €192.9 billion a year earlier. The EU’s monthly external trade deficit widened to €25.2 billion, compared with €7.5 billion in August 2025.
These figures cover all merchandise imports, not just goods subject to CBAM. Energy and machinery accounted for substantial movements in the overall trade balance, making it inappropriate to treat the aggregate figures as evidence of changes in carbon-border-exposed imports.
Overall import growth does not establish changes in CBAM market shares
China supplied €53.1 billion of EU imports in August, up 19.7% year on year. Imports from Türkiye reached €7.3 billion, an increase of 0.7%, while imports from India totalled €6.0 billion, up 18.3%.
The figures describe total merchandise trade, including numerous products outside CBAM’s scope. Customs values also measure monetary value rather than physical tonnage or embedded emissions. Growth in imports from a trading partner therefore does not necessarily indicate an increase in that country’s share of a particular covered product market.
A carbon-relevant comparison requires product-level customs data, consistent origin definitions and a clear distinction between goods already covered by CBAM and downstream products that have been proposed for inclusion.
CN-code precision is essential for steel and aluminium comparisons
To assess supplier shares in covered steel products, analysts must aggregate the relevant eight-digit Combined Nomenclature (CN) codes listed in Annex I, apply consistent reporting definitions and distinguish existing covered products from proposed downstream additions.
For aluminium, unwrought metal classified under CN 7601 cannot be combined indiscriminately with fabricated products classified under other headings. Calculating a weighted average customs price in euros per tonne also requires comparable import values and net mass.
A robust comparison should include the latest month, the preceding month, the corresponding month a year earlier and year-to-date figures to help distinguish sustained changes from short-term volatility. For each country of origin, it should report shares of extra-EU import tonnage and value, changes in those shares in percentage points, changes in tonnes and implied customs unit values.
Goods originating in Norway, Iceland, Liechtenstein and Switzerland, which benefit from relevant exemptions under the applicable CBAM framework, also require separate treatment when interpreting potential carbon liabilities. Broad Harmonized System chapter statistics can provide context, but they cannot replace an auditable, product-level calculation.
Historical steel data reveal competition among major suppliers
Historical trade figures already show a closely contested European flat-steel import market. EUROFER’s European Steel in Figures 2026, using 2025 trade data, put EU imports of flat steel products at approximately 23.1 million tonnes.
Türkiye supplied 3.28 million tonnes, or 14.2% of the total, while South Korea supplied 3.24 million tonnes, or 14.0%. These figures describe a broader group of finished flat products, rather than a CN8-filtered total of CBAM-covered imports. They also do not establish market shares for October 2026.
The distinction matters because historical product-group totals cannot be used directly to determine the current competitive position of individual exporters under the definitive carbon-border regime.
Inventories, safeguards and weak demand complicate trade signals
In its Oct. 1 market outlook, EUROFER reported that EU steel imports declined 5% in the first half of 2026, following an exceptional surge in late 2025, while exports fell 20%.
The reversal in imports may partly reflect inventory accumulation ahead of the definitive CBAM phase. However, it is also consistent with weak steel demand, trade safeguards, price movements and logistics constraints. Assigning the change to a single cause would require shipment-timing and product-level evidence.
Comparisons between countries are further complicated by the location of processing activities. Steel slab imported from one country and converted into a finished product in another may acquire a different non-preferential origin from that of its precursor. Customs statistics alone do not reveal the complete production and emissions chain.
Changes in customs unit values also require careful interpretation. They may reflect different product grades, alloy content or delivery terms rather than changes in underlying pricing pressure.
Customs origin must be separated from shipping and invoicing routes
The distinction between customs origin and shipping route becomes particularly important when suppliers establish distribution centres within the EU or in neighbouring countries. A shipment invoiced through an intermediary does not automatically acquire that intermediary’s country of origin.
Analysts need the reported partner-origin field, the applicable non-preferential origin rules, the relevant import regime and any applicable exemptions. Treating a redistribution hub as the producing country can distort national market shares and lead to incorrect conclusions about which exporters are gaining business at the expense of others.
A reproducible assessment should therefore document the data-extraction date, exact CN8 selection, monthly coverage, provisional-data flags and the formula used to calculate unit values.
For example, an increase in a supplier’s share from 10% to 12% represents a gain of two percentage points, not a 20-percentage-point increase. Similarly, rising customs value alongside declining tonnage indicates a change in value per unit or product mix, rather than necessarily greater physical market penetration.
These distinctions are essential when assessing whether observed trade changes reflect CBAM, broader market conditions or a combination of factors.
Exporters face a combined test of price, emissions data and reliability
For European buyers sourcing from Serbia, Montenegro, Türkiye, India, China and Ukraine, the commercial test increasingly combines competitive delivered prices, reliable emissions data and predictable supply.
In 2026, these factors may influence procurement decisions before definitive evidence of a CBAM-driven market-share shift becomes available. Establishing the mechanism’s competitive effects requires analysis at CN-code level, with consistent treatment of physical volumes, customs values, product origin and applicable exemptions.
The latest aggregate trade figures provide context for the changing European import market, but they do not establish a ranking of CBAM winners and losers.
