Germany represented 12.7% of the European Union’s extra-EU imports of goods under existing Carbon Border Adjustment Mechanism (CBAM) codes in 2025, equivalent to around 14.1 billion euros, based on a rounded Eurostat country share. The scale of demand matters for steel and aluminium suppliers because imported material can pass through several companies before entering automotive, machinery and infrastructure supply chains.
A vehicle manufacturer may source pressings, castings, structural parts and subassemblies from tier-one or tier-two suppliers rather than buy the originating metal. Those suppliers may in turn buy sheets and profiles from processors using a mix of imported and domestically produced feedstock. Each stage has its own contract terms, inventory policy and access to emissions documentation.
As a result, the company expected to surrender CBAM certificates may not have enough negotiating power to pass the full cost down the supply chain. Low-emission imported material backed by credible installation data may compare differently under CBAM from high-emissions products relying on default values. For manufacturers, the risk is not only a higher price for imported metal, but also a less transparent supply base where gaps in evidence can create cost and delivery uncertainty.
Processors and market conditions
Novelis manufactures and recycles aluminium products for automotive and packaging markets at its German operation in Nachterstedt. Klöckner & Co operates a network of metal-processing and service-centre businesses. These disclosures show the relevance of intermediate processors, but do not establish the origin of every tonne supplied to a vehicle maker.
The European Steel Association reported weak demand, low capacity utilisation and continued pressure on exports in 2026, indicating that carbon policy is only one factor in a difficult steel-market environment. EU producers also face energy, wage and capital costs, while the gradual phase-out of EU Emissions Trading System free allowances is changing their exposure.
A meaningful German CBAM study would combine CN8 import values with metal-processing locations, component procurement and the identities of actual buyers where public documentation supports a link. It would also test whether contracts explicitly separate raw-material prices from carbon adjustments.
