CBAM for steel fastener buyers: five questions before ordering

Proposed downstream expansion remains separateProposal — not law

COM(2025)989, procedure 2025/0419(COD), is an ongoing proposal to extend CBAM to selected additional downstream goods from 1 January 2028. It has not been adopted, so proposed additions must not be treated as current scope.

That proposal status does not make every finished steel article proposal-only. CN heading 7318 is already printed in the current Annex I. The separate proposal should be monitored for other products without changing the current 7318 record.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

Question 1 — Which exact customs code and description will be used?

Current Annex I lists CN heading 7318 for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles of iron or steel. The heading-level listing is the adopted source anchor; it is not a substitute for the full code and product description used in the customs record.

Record the code supplied by the customs-classification process and check it against the current Annex I snapshot in the CBAM goods checker. CBAM Pulse can show the reviewed scope record for an entered code, but it does not assign or confirm a customs classification.

Question 2 — Which installation and production process made the fasteners?

Ask the supplier to identify the installation and the production process behind the goods rather than providing only a company-level carbon figure. Keep the product, installation, process and reporting period tied together so the evidence can be reviewed as one traceable record.

For multi-site or outsourced production, record which operation produced the ordered goods and which party supplied each emissions input. Do not infer that one corporate average describes every installation or production route.

Question 3 — Which precursor and production-boundary records are available?

Where the applicable method treats the fasteners as complex goods, ask which relevant precursors were used, the total mass required, their source installations and production processes, and the basis of their embedded-emissions values. Commission Implementing Regulation (EU) 2025/2547 requires source-specific monitoring data and defines the precursor-mass parameter in its calculation rules.

Keep cut-offs, scrap, residues, outsourced processing and other boundary notes explicit rather than assuming they are captured by a product total. The supplier-request template and reporting-evidence checklist keep those records separate for later review.

Question 4 — Is each emissions value actual, default or still unavailable?

Label each figure by its evidence basis and reporting period. Supplier-reported actual data, an applicable official default and a value that is not yet available are different states and should not be blended into one unlabelled number.

A product carbon footprint, environmental declaration or ISO-related document may contain useful evidence, but its title alone does not establish that the data satisfies the CBAM calculation or verification rules. Record the underlying method, boundary, installation and supporting source instead of treating the document label as a verdict.

Question 5 — What has been independently verified, and what still needs review?

Separate supplier-provided information from accredited verification. Commission Implementing Regulation (EU) 2025/2546 and the Commission verification page describe the verification route; a supplier statement or consultancy report is not automatically an accredited CBAM verification opinion.

Use the supplier-request template to collect the missing fields, carry source references and open gaps into the preparation workspace, and retain the verification status as a factual record. CBAM Pulse organises preparation evidence; it does not verify emissions, certify the supplier, decide applicability or make a filing conclusion.