CBAM reporting from October 2023: what importers of steel strapping components need

On 1 October 2023 the EU’s Carbon Border Adjustment Mechanism (CBAM) entered its transitional period. From that date until the end of 2025, importers of covered goods must report the greenhouse gas emissions embedded in them, quarter by quarter, without paying for those emissions. Iron and steel is one of the covered sectors, and the list reaches beyond mill products into finished articles.

For distributors and manufacturers importing metal strapping components into the EU, the first questions are whether their goods are in scope and whether their suppliers can provide the data. This article works through both. It is not customs or legal advice.

The timetable

Regulation (EU) 2023/956, published in the Official Journal on 16 May 2023, establishes CBAM. The Commission’s Implementing Regulation (EU) 2023/1773, adopted on 17 August 2023, sets the reporting rules for the transitional period. According to the Commission’s announcement of 17 August 2023:

• the transitional period runs from 1 October 2023 to the end of 2025;
• importers collect data for the fourth quarter of 2023 from 1 October;
• the first quarterly report is due by 31 January 2024;
• no financial adjustment is payable during the transitional period.

The Commission published guidance for EU importers and for non-EU installations on the same day, and both are worth reading alongside the legal texts.

Which strapping components fall within CBAM?

Annex I of Regulation 2023/956 lists the covered iron and steel goods by Combined Nomenclature (CN) code. It includes Chapter 72, with specified ferro-alloy exceptions, and a series of Chapter 73 headings, among them 7318 (screws, bolts, nuts and similar fasteners) and 7326, “Other articles of iron or steel”.

Item	Material	Scope question to settle
Galvanized and phosphated wire buckles	Steel wire	Which CN code applies, and is it listed in Annex I?
Sheet metal clips	Steel sheet	The same question
Steel strapping seals	Galvanized steel sheet	The same question
Steel strap	Flat-rolled steel	Steel strip is normally classified in Chapter 72
PET and woven polyester strap	Plastics	Not iron or steel, so outside the iron and steel list

Classifying a specific item is the importer’s responsibility and should be confirmed with a customs adviser at the full eight-digit CN code. If the code falls within Annex I, the goods are CBAM goods for reporting purposes. A classification settled years ago for duty purposes deserves a second look, because it also decides a reporting obligation from October 2023.

What the report contains

Implementing Regulation 2023/1773 specifies the data. For each CBAM good, the report covers the CN code, country of origin and quantity; the installation where the goods were produced and its production route; the direct and indirect emissions embedded in them; and any carbon price paid in the country of origin. The methodology treats goods such as steel articles as complex goods, whose embedded emissions include those of the precursor materials consumed in making them.

That has a practical consequence for components. A buckle maker forms wire it has bought; a seal or clip maker presses steel sheet. The emissions data for the finished component therefore depends partly on information from the steel producer upstream, passed through the component manufacturer to the EU importer.

Default values and estimates in the early reports

The rules allow some flexibility while supply chains adjust. Article 4(3) of the implementing regulation lets declarants who lack the required information use other methods, including default values made available by the Commission, until 31 July 2024, provided they state the method used. Article 5 allows up to 20% of the total embedded emissions of complex goods to be based on estimates provided by installation operators. Article 16 sets penalties of between EUR 10 and EUR 50 per tonne of unreported emissions where a report is not submitted, or an incorrect one is not corrected after the authority opens a correction procedure.

The flexibility is temporary. Importers who start the supplier conversation in October 2023 will be better placed than those who rely on default values until the window closes.

Questions to put to a component supplier

• Can you identify the installation where each component was made, and its production route?
• Can you obtain embedded emissions data from your steel wire or sheet supplier, and in what form?
• Will the data follow the methodology in Implementing Regulation 2023/1773, and who will prepare it?
• How will data be matched to shipments: per order, per quarter or per production period?
• Who is the contact for CBAM data requests, and how quickly can they respond?

Record the answers alongside the commercial terms. A supplier that cannot yet provide data may still be the right supplier, but the importer then needs to plan for default values and their time limit.

Keep the commercial and technical records together

CBAM adds a data stream to each import; it does not change the component. The part number, drawing revision and approved specification remain the basis of the order. Our international procurement guide sets out the documents to align for a first order, our note on what a component manufacturer should make clear lists questions that sit naturally beside the CBAM ones, and the German technical RFQ guide shows how to structure the technical side of the same enquiry.

Bringing CBAM questions into the enquiry

The YAKU catalogue covers metal components such as galvanized wire buckles, sheet metal clips and steel strapping seals. If you import into the EU and need to discuss CBAM data alongside a quotation, say so in your enquiry so that the request can be reviewed together with the component specification.