If you sell steel pipes, fittings, flanges, fasteners or flat products to Europe, your buyers have started asking a new question: "What are the embedded emissions of this product?" That question comes from CBAM, the EU's Carbon Border Adjustment Mechanism. Indian exporters who prepare early will keep European customers; those who don't may find themselves priced out.
Note: CBAM rules have been amended since they were first adopted, and implementing details continue to evolve. Treat this as an overview and confirm current requirements with your EU buyers and official EU guidance.
What is CBAM?
CBAM puts a carbon price on certain imports into the EU, so that imported goods face a carbon cost similar to goods made inside the EU under the EU Emissions Trading System (ETS). It covers carbon-intensive sectors including iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
For steel, the scope includes many products in Chapters 72 and 73 — semi-finished steel, flat products, bars, sections, tubes and pipes, many fittings and fasteners. Check whether your exact HS/CN codes are covered; see HS codes for steel pipes, fittings and flanges.
Timeline in brief
- Transitional phase (October 2023 – December 2025): EU importers filed quarterly reports on embedded emissions. No payment.
- Definitive phase (from 1 January 2026): importers must be authorised CBAM declarants and will have to surrender CBAM certificates for the embedded emissions of covered goods, with the first annual declarations and certificate purchases for 2026 imports falling in 2027.
- Gradual phase-in: the CBAM cost rises over the coming years as free ETS allowances for EU producers are phased out.
The EU has also introduced simplifications, including a threshold that exempts importers bringing in only small quantities of covered goods each year. Larger industrial buyers will still be fully covered.
Who pays — and why it still matters to you
Legally, the EU importer is responsible for CBAM declarations and certificates — not the Indian exporter. But in practice:
- the importer needs emissions data from you to declare accurately,
- if you cannot provide verified data, the importer may have to use default values, which are designed to be conservative and can make your product more expensive to import,
- buyers will compare suppliers on total landed cost including CBAM.
So CBAM becomes a competitiveness issue for every Indian supplier selling into Europe.
What are embedded emissions?
Embedded emissions are the greenhouse gases released in making a product, expressed as tonnes of CO₂ per tonne of product. For steel, they depend heavily on the production route:
- Blast furnace–basic oxygen furnace (BF-BOF): typically the highest emissions.
- Electric arc furnace (EAF) with scrap: usually much lower, depending on electricity source.
- DRI-based routes: depend on whether coal or gas is used.
For downstream products such as pipes and fittings, embedded emissions include those of the steel input plus your own processing emissions (fuel for furnaces, heat treatment and so on).
What data EU buyers will ask for
- installation (plant) details and location,
- production route and process description,
- direct emissions from your processes,
- emissions embedded in purchased precursors (for example, steel billets, coils or tubes from your mill),
- electricity consumption where relevant,
- any carbon price already paid in the country of origin,
- verification by an accredited verifier in the definitive phase.
How to prepare your company
- Map your products and HS codes sold to the EU.
- Ask your steel suppliers (mills) for emissions data on the material you buy. Your numbers depend on theirs.
- Measure your own energy use — fuel, gas, electricity — per tonne of output.
- Appoint a CBAM owner inside your company.
- Work with a consultant or verifier familiar with EU CBAM methodology.
- Create a standard CBAM data sheet to share with EU buyers.
- Explore lower-carbon inputs — EAF steel, renewable electricity, efficient furnaces.
Turning CBAM into a sales advantage
Most competitors will be slow. If you can tell a German or Italian buyer, "Here is our verified emissions data, and our product carries lower embedded emissions than default values," you remove a headache from their purchasing team. Mention CBAM readiness on your website and in your proposals. Our guide to finding steel buyers in Europe shows where to use this advantage.
On your website, add a sustainability or compliance page — it is also a strong trust signal. See trust signals every manufacturer website needs.
Frequently asked questions
Do Indian exporters pay CBAM?
The EU importer is legally responsible, but the cost affects your competitiveness, and buyers need your emissions data.
Does CBAM cover steel pipes and fittings?
Many iron and steel products in Chapters 72 and 73, including tubes, pipes and many fittings, are covered. Check your specific codes.
What happens if I can't provide emissions data?
The importer may have to use default values, which are typically less favourable and can raise the cost of your product in the EU.
Is CBAM only for large mills?
No. Any exporter of covered goods to the EU, including traders and small manufacturers, will be asked for data by their buyers.
Key takeaways
- CBAM moved into its definitive, paying phase from 2026.
- EU importers pay, but they need emissions data from you.
- Default values can make your product costlier — real data can make it competitive.
- Start collecting data from your mills and your own processes now.
Europe remains a valuable market for Indian metal products. CBAM-ready suppliers will be the ones still shipping there in five years.
