A surprising amount of CBAM trouble starts with a deceptively simple question: is this product actually covered? The regulation answers it by CN code — the Combined Nomenclature classification used in EU customs — listed in Annex I of the CBAM Regulation. That detail shapes everything downstream.

Scope is defined by code, not description

CBAM does not cover “steel” or “aluminium” as loose categories. It covers a specific list of goods identified by CN code. The practical consequences:

Two products that look almost identical can fall on opposite sides of the scope line if they carry different CN codes.
A product’s CBAM status follows its customs classification, so a misclassification at import is also a CBAM problem.
The covered list extends beyond raw metal into many semi-finished and finished goods, so importers who think of themselves as buying “products,” not “steel,” can still be in scope.

The covered sectors are cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. For steel importers and aluminium importers, the iron/steel and aluminium chapters of Annex I are the ones to work through.

Why we don’t reproduce the code list here

The authoritative list lives in Annex I of the CBAM Regulation, and it is exactly the kind of thing that should be read from the official source rather than a third-party copy that may be out of date. Always confirm scope against the current consolidated regulation and the European Commission’s CBAM guidance. What we can offer is the method for turning that list into something usable for your business.

Building a defensible in-scope register

Rather than asking “are we affected by CBAM?” once, build a register you can maintain and defend:

List your actual goods with the CN codes used on your customs declarations.
Match each against the covered codes in Annex I. Flag exact matches, near-misses, and anything ambiguous.
Record the decision and the reasoning for each — especially borderline cases — so a reviewer can see why you classified as you did.
Separate confirmed from uncertain. Keep open classification questions in a visible list, not buried in confirmed data.
Re-check on change. New products, new suppliers, or reclassifications should trigger a review.

Classification is a documentation task, not a one-time answer. The value is a living register that ties each product to a CN code, an in-scope decision, and the reasoning — ready for your customs broker or adviser to review.

How this connects to the rest of CBAM

The in-scope register is the foundation. It determines which shipments need supplier emissions data, which feed your evidence archive, and ultimately what goes into your annual declaration (deadlines here). Get classification wrong and every downstream step inherits the error.

Where CarbonBorder Desk fits

We build and maintain the in-scope register as part of the operational file — matching your goods to CN codes, logging the reasoning, and keeping borderline questions visible for your adviser. We do not provide formal tariff classification rulings or legal opinions; we structure the information so the people who do can review it quickly. This is typically part of a pilot diagnostic.

Not legal or customs advice. This page is general operational information about the EU Carbon Border Adjustment Mechanism, accurate to the review date above. CBAM rules and figures change — always confirm current obligations with official EU guidance and your national competent authority. CarbonBorder Desk prepares documents and evidence; it does not file declarations or give legal opinions.