CBAM Product Scope: Tracking the Expansion to Processed Iron and Steel Products

How Might Goods Manufactured from Metals Enter the Scope?

Distinguishing Between Existing Rules and Scope Expansion Proposals

The inclusion of a processed metal product into CBAM does not occur spontaneously simply because it “uses steel.” The current scope derives its authority entirely from the enforced Annex I list of Regulation (EU) 2023/956. Exporters must not confuse ongoing studies or proposals aiming to encompass downstream products with the existing liability list until such expansions achieve formal adoption and applicability.

When reviewing a proposal, merely scanning product names proves insufficient. Stakeholders need to analyze the proposed CN codes, effective dates, emission calculation methodologies, and transitional provisions collectively. This comprehensive approach enables a company to separate the rules governing today’s shipments from data requirements that may emerge in the future.

How Should Claims Like “Approaching 500 Products” Be Verified?

An assertion such as “500 products” fails to illustrate the true magnitude of the scope without citing a source and counting methodology. The same claim could be tallying CN codes, commercial product variants, or subheadings within a draft text. These metrics are not interchangeable.

To verify such statements, businesses must examine the underlying official EU text, its code list, and its legal status. They should ask: Is this a consultation document, a Commission proposal, or a published legislative amendment? Furthermore, any comparison requires subtracting the processed goods already present in the current Annex I. Companies should never treat a figure unsupported by an official code list as definitive data in their scope analyses.

Key Considerations When Mapping Turkish HS Codes (GTİP) to CN Codes

The Turkish Customs Tariff Statistics Position (GTİP) utilized in export declarations does not correspond to the exact same document field as the CN code used for EU imports. Instead of automatically assuming the final digits of the GTİP match the CN code, stakeholders must conduct mapping based on the good’s technical specifications and both parties’ current tariff schedules. Different alloys, profiles, or processing methods sold under identical commercial names might mandate distinct classifications.

Companies benefit from maintaining product records that combine the Turkish HS code, the CN code used by the EU client, the product description, and the technical documentation supporting the classification. The A.TR movement certificate cannot substitute this review: The document pertains strictly to free circulation status within the customs union and does not eliminate the need for product code and emission assessments under CBAM.

What Are the Obligations and Costs for Exporters in Turkey?

EU Importer Obligations versus the Turkish Manufacturer’s Role in Providing Data

The primary counterpart for CBAM during EU importation is, where applicable, the authorized CBAM declarant. Businesses must verify this party’s obligations regarding declarations, embedded emissions, and certificate processing against current official EU regulations. As a general rule, a Turkish manufacturer does not surrender certificates on behalf of the EU; conversely, the EU client will request facility-based data from the manufacturer to complete the requisite calculations.

Exporters must consult current official EU legislation to confirm any applicable thresholds for the relevant importer, alongside potential exemptions concerning electricity and hydrogen. Rather than making per-shipment assumptions during threshold checks, stakeholders must factor in the EU importer’s total imports and the nature of the goods. Within this framework, a Turkish supplier can clarify the exact scope of data requests with their client.

Emission Data, Verification, and Production Facility Records

For the manufacturer, preparation centers around records that map the product to its specific production facility. Companies must document the inputs used, production volumes, fuel and electricity consumption, process data, and relevant precursor materials. If multiple facilities manufacture identical products, a single corporate average might fail to satisfy facility-based reporting requirements.

Regulation (EU) 2023/956 provides the framework for determining embedded emissions during the definitive period; companies must confirm exact verification conditions through current official EU texts. Consequently, rather than merely sending a client a total carbon footprint figure, manufacturers need to prepare a comprehensive file detailing the reference period, facility, calculation method, and supporting evidence. The availability of default values for missing data does not render measured facility data irrelevant to final pricing.

The Impact of Carbon Costs on Pricing and Competition

Businesses must check current official EU rules to see how CBAM certificate prices correlate with the EU Emissions Trading System. The final payable amount cannot be derived solely from a product’s weight; factors such as the associated embedded emissions, applicable corrections, and the documentation of an eligible carbon price effectively paid in the country of origin significantly influence the calculation. Therefore, no single flat tariff exists for the carbon cost of exporting from Turkey to the EU across all steel or aluminum products.

The exporter and the EU buyer can explicitly define within their contracts who provides the emission data, who bears the verification costs, and how to manage CBAM-driven price fluctuations. Addressing the commercial consequences of data unavailability prior to shipment proves far more practical than engaging in retroactive price negotiations.

How Does the “Made in EU” Debate Differ from CBAM?

Recognizing the Two Concepts as Distinct Policy Tools

CBAM is a regulation whose scope and mechanisms are defined in Regulation (EU) 2023/956, targeting embedded emissions in imported goods. Conversely, Made in EU is an expression utilized within industrial and supply policy debates surrounding the prioritization of European manufacturing. Standing alone, this phrase indicates neither that a product has entered the CBAM Annex I list nor that Turkish-origin goods face a new carbon obligation.

Any production location requirement within a public procurement, subsidy program, or industrial policy proposal demands separate evaluation based on its specific text. Treating such requirements as part of the same legal framework as the CN code list used in CBAM yields erroneous scope conclusions for the exporter.

Shared Risks for Turkish Industry and EU Supply Chains

While the two debates rely on divergent instruments, they frequently surface together during EU buyers’ procurement decisions. If a steel component manufactured in Turkey falls under CBAM, the quality of its emission data directly impacts cost calculations. Meanwhile, that same component’s eligibility for an EU purchasing or support condition relies entirely on the specific rules of that individual condition, if applicable.

A business that maintains this distinction can provide its client with two distinct answers: “Under which CN code does the product fall within CBAM?” and “What production location or local content requirement does the relevant purchasing program demand?” Resolving the first question does not automatically answer the second.

What Steps Should Exporters and Administrations Take?

Product Code, Data, and Supplier Readiness Checklist for Businesses

The preliminary task involves creating an up-to-date mapping table of products sold to the EU:

• Record the technical description, the Turkish HS code (GTİP), and the CN code used in EU importation for each product.
• Compare the CN code against the currently enforced Annex I list of Regulation (EU) 2023/956.
• Link in-scope products to their specific production facility, production period, and the precursor materials utilized.
• Identify the sources of fuel, electricity, and process data, determining precisely which information requires procurement from suppliers.
• Clarify data formats, verification procedures, and the contractual division of responsibilities with the EU client.

Companies can utilize this checklist for existing products without waiting for new scope announcements. During evaluations for potential expansion, businesses can append separate fields for “under proposal” and “enforced” statuses to the same table.

Negotiation and Compliance Priorities Regarding Turkey’s Commercial Interests

For public administrations and sector organizations, the concrete starting point is compiling—on a product group basis—the challenges exporters encounter in HS code-CN code mapping and their facility data collection needs. During technical discussions with the EU, these records facilitate debates over how proposed new codes affect intermediate goods from Turkey and evaluate manufacturers’ access to calculation rules.

These same records prove highly valuable for individual businesses, answering critical questions: Which input data remains with the supplier? At which production stage do measurement deficiencies occur? What specific information does the EU buyer require? A robust corporate compliance strategy must generate answers to these questions at both the product and facility levels.

How Should Official EU Legislation Be Monitored for New Scope Decisions?

Upon encountering news of a newly covered product, stakeholders must first verify the current text and Annex I of Regulation (EU) 2023/956 on EUR-Lex. Following this, they need to ascertain whether the text outlining the change constitutes a mere proposal or a formally published regulation in the Official Journal of the EU, meticulously reviewing effective dates and applicability timelines. Companies should also track the Commission’s CBAM implementation notices separately for updates on technical calculations and declaration processes.

The subsequent step involves generating an HS code-CN code-Annex I mapping table, beginning with the company’s highest-volume exports. By appending the corresponding production facility and the party responsible for emission data to each row, businesses can effectively evaluate both present obligations and future scope amendments through the lens of concrete products.

NoteThis content is for general informational purposes only and does not substitute for customs brokerage or legal advisory services.