Iron & steel production has different emissions sources depending on the raw material and production technology used. The emissions gap between integrated facilities producing from ore and electric arc furnace facilities producing from scrap is quite significant.

Crude steel, semi-finished products, and certain finished products (such as screws, bolts, and fasteners) are all subject to reporting under CBAM — which can mean collecting data at multiple points in your supply chain.

Steel produced via the blast furnace–basic oxygen furnace (BF-BOF) route has high direct emissions due to coking coal use. Steel produced from scrap via the electric arc furnace (EAF) route has lower direct emissions, but indirect emissions become significant depending on the electricity source used.

This difference means the production route you use directly affects your CBAM cost — EAF facilities running on a clean electricity source can gain a meaningful advantage.

In iron & steel CBAM reporting, direct emissions (fuel combustion, process emissions) and indirect emissions (purchased electricity) are calculated and reported separately. This split requires careful data management, particularly at facilities spanning multiple production stages.

If your supply chain involves intermediate products from different facilities, you'll need to track the embedded emissions of each stage separately and combine them correctly in the final product.

Iron & steel is one of the sectors with the broadest CBAM coverage — not just raw and semi-finished products, but certain downstream products fall within scope too. That can mean tracking emissions deeper into your supply chain.

Clarifying exactly which scope category your exported product falls into is the first step in determining the size of your reporting obligation.