Insights / CBAM
Do Indirect Emissions Count for Steel and Aluminium Under CBAM?
Do indirect emissions from the electricity used in production count in the CBAM embedded emissions of steel or aluminium?
No. Annex II of Regulation (EU) 2023/956 lists iron and steel, aluminium, hydrogen and electricity (CN 2716 00 00, added by Regulation (EU) 2025/2083) as goods for which only direct emissions are taken into account (Article 7(1)). Indirect emissions count only for cement and fertilisers.
What the act says
- Article 7(1) and Annex II: Direct emissions only for iron and steel, aluminium, hydrogen and electricity.
- Cement and fertilisers: The only CBAM goods whose embedded emissions include indirect emissions.
What to do
- Ask steel and aluminium suppliers for direct embedded emissions per tonne, by installation and production route.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) 2025/2083 amending the CBAM Regulation (CELEX 32025R2083)
Last checked against the act text on 2026-10-20. For information only, not legal advice.