Reliable assessments of imports covered by the European Union’s Carbon Border Adjustment Mechanism (CBAM) require analysis at the eight-digit Combined Nomenclature (CN) level. The 2025 import aggregate was €111.23 billion for goods specified in Annex I of the CBAM Regulation, but broad customs chapters can include products that are not covered.
Counting an entire chapter as exposed to a carbon-border charge can therefore misstate the scale of affected trade. A reliable product ranking must use a consistent geography, year, trade flow and classification, rather than combine figures drawn from different customs codes or markets.
The largest structural categories include iron and steel products, primary aluminium, semi-finished metal products, electricity, fertilisers and clinker. Within those groups, the value of individual product flows can differ sharply: EU extra-EU imports of unwrought non-alloyed aluminium under CN code 7601 10 90 were about €7.51 billion in 2025.
Trade figures also need comparable scopes. A reported value for a specific flow of hot-rolled steel from Türkiye cannot be treated as the EU-wide total for the relevant customs code. Primary metal, billets, sheets, tubes, profiles and fasteners may also have different embedded-emissions boundaries and process requirements.
Product distinctions matter in other sectors. For fertilisers, identifying urea separately from other nitrogen products affects which processes and precursors need assessment. Electricity is classified under CN 2716 00 00 and requires a separate evidence chain covering grid scheduling, metering and emission factors, as well as direct power-purchase contracts where applicable.
Classification can determine whether an importer exceeds the 50-tonne annual de minimis threshold for the four mass-based sectors. Electricity and hydrogen are not covered by that exemption.
Companies need to reconcile product master data and customs declarations with their CBAM records before calculating emissions or certificates. Incorrect coding can create liability, delay release for free circulation or distort management forecasts.
A complete CN8 intelligence table should set out product descriptions, annual and quarterly values, net mass, non-EU origin, the reporting EU member state, named installations where known, main industrial processors and downstream end uses. It should also flag exempt origins and pending legislative amendments. Such data underpin meaningful rankings of importers and final beneficiaries; attempts to identify those companies from aggregated customs figures alone remain provisional.
