Quick guide to CN codes for EU CBAM goods

How to identify your CBAM imports, with definitions of CN, HS and TARIC classifications.

If you import goods into the EU, it’s your responsibility to establish whether they’re subject to the EU Carbon Border Adjustment Mechanism (EU CBAM).

Otherwise you could face fines for missing the reporting deadline on 31st January 2024.

At CarbonChain, we help manufacturers and traders navigate and automate their CBAM reporting. This quick guide helps companies solve the first challenge: identifying which goods fall under CBAM and what their CN codes are.

Are my goods covered by EU CBAM?

  • The EU CBAM focuses on high-emitting industries, including cement, iron and steel, aluminum, fertilizers, hydrogen and electricity.
  • However, not every product in those industries are included. For example, car doors made from aluminum are excluded, while nuts and bolts are included.

Do you know your CN codes?

If you know the CN codes of your goods, it's easy to identify whether they're included in the EU CBAM. All products are listed in Annex I of the EU CBAM implementing regulation.

Don’t know your CN codes? Read on.

What are the common product classifications (CN, HS, TARIC)?

CN codes are related to TARIC and HS classifications. The EU CBAM implementing regulation refers to HS headings as well as CN codes, and you can work out your product's CN code if you know its TARIC code.

  • Combined Nomenclature (CN) is a tool for classifying goods, set up to meet the requirements of both the Common Customs Tariff and of the EU's external trade statistics.
  • Harmonized System (HS) is a globally standardized numerical method of classifying traded products managed by the World Customs Organization.
  • Integrated Tariff Rate System (TARIC) is a system used in the EU to determine the taxes and duties applicable to the import or export of goods.

How are HS, CN, TARIC and HTS codes related?

For any given product, the first few digits of its HS, CN and TARIC codes are the same, as follows:

Diagram showing the structure of CN, HS and TARIC codes to help CBAM importers establish whether their goods are covered by the regulation. A CN code is made up of an HS chapter, HS heading, HS subheading and a CN subheading. A TARIC code contains extra digits at the end.
A CN code is made up of an HS chapter, HS heading, HS subheading and a CN subheading. A TARIC code contains extra digits at the end.

In summary:

  • HS headings are 4 digits long
  • HS codes are 6 digits long
  • CN codes are 8 digits long
  • TARIC codes are 10 digits long

It's also worth being aware of the Harmonized Tarriff System (HTS): a 10-digit classification system used in the US to help determine customs duties to be paid on imports. HTS codes are 10 digits long, and the first 6 digits are the HS code that align to the EU’s classification system.

For more information on these codes, please consult the following resources: CN, HS, TARIC, HTS.

How do CN codes align to the EU CBAM?

EU CBAM goods are identified by their CN code.

However, in EU CBAM implementing regulation, certain products (e.g. unwrought aluminium, code 7601) are listed by their 4-digit HS heading, rather than their 8-digit CN code.

  • Important: If your product's full CN code is not listed but the HS heading is (e.g. your product's code is 7601 00, but only 7601 is listed), then your product is covered by the CBAM.

How do I find out my product's CN code for EU CBAM?

If you operate an installation that may be producing CBAM goods, talk with your compliance and legal department. They will likely have been involved in determining and declaring the CN code of the products manufactured at your facility.

If you import goods that may be subject to CBAM, consult with your customs, procurement or logistics department. They will have information on the CN codes that sit within your import declarations (box 33 of an EU customs declaration).

What if my product contains products with CBAM CN codes?

Some products don't have a CBAM-covered CN code, but contain other products that do. We often get asked whether CBAM applies in this case.

The answer is no. The EU CBAM is only concerned with the final CN code of the good imported into the EU — and these are primarily ‘simple goods’.

In the case of car manufacturers:

  • Steel sheets are covered by CBAM but car bodies made from steel aren't.
  • Aluminium sheets are covered by CBAM but car doors made from them aren't.

What matters is what the CN code of the good is at the moment it crosses the border. It is irrelevant under CBAM if you are importing a good whose CN code is not listed, even if it’s made from a good whose CN code is listed.

Diagram showing which goods in an aluminum supply chain are included and excluded from CBAM declarations. Imported aluminium ingot must be declared under CBAM, imported aluminium sheet must be declared under CBAM, but imported aluminium car doors are not covered by CBAM despite being made from goods that are covered
Diagram showing example of aluminium goods included and excluded from CBAM declarations
Diagram depicting steel goods included and excluded from CBAM declaration rules. Imported crude steel and steel sheets are covered by CBAM but imported steel car bodies are not, even if they're made of CBAM-covered goods.
Diagram showing example of steel goods included and excluded from CBAM declarations

My product has a CBAM CN code. What now?

Importers

Found your CN codes?

If you’ve established that you import CBAM-covered goods, then start creating your first declaration to meet the 31st January 2024 deadline.

Installations

If you’ve established that you produce CBAM goods, then prepare for your customers to start requesting your emissions data. They will not be able to continue sourcing your products if you don’t provide this data.

Need help measuring emissions in compliance with CBAM?

FAQ

Which aluminum product CN codes are included in EU CBAM?

Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.

  • 7601 – Unwrought aluminium
  • 7603 – Aluminium powders and flakes
  • 7604 – Aluminium bars, rods and profiles
  • 7605 – Aluminium wire
  • 7606 – Aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm
  • 7607 – Aluminium foil (whether or not printed or backed with paper, paper-board, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0,2 mm
  • 7608 – Aluminium tubes and pipes
  • 7609 00 00 – Aluminium tube or pipe fittings (for example, couplings, elbows, sleeves)
  • 7610 – Aluminium structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns); aluminium plates, rods, profiles, tubes and the like, prepared for use in structures
  • 7611 00 00 – Aluminium reservoirs, tanks, vats and similar containers, for any material (other than compressed or liquefied gas), of a capacity exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7612 – Aluminium casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquefied gas), of a capacity not exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7613 00 00 – Aluminium containers for compressed or liquefied gas
  • 7614 – Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated
  • 7616 – Other articles of aluminium

Which iron and steel product CN codes are included in EU CBAM?

Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.

  • 2601 12 00 – Agglomerated iron ores and concentrates, other than roasted iron pyrites
  • 7201 – Pig iron and spiegeleisen in pigs, blocks, or other primary forms. Some products under 7205 (Granules and powders, of pig iron, spiegeleisen, iron, or steel) may be covered here.
  • 7202 1 – Ferro-manganese
  • 7202 4 – Ferro-chromium
  • 7202 6 – Ferro-nickel
  • 7203 – Ferrous products obtained by direct reduction of iron ore and other spongy ferrous products
  • 7206 – Iron and non-alloy steel in ingots or other primary forms (excluding iron of heading 7203)
  • 7207 – Semi-finished products of iron or non-alloy steel
  • 7218 – Stainless steel in ingots or other primary forms; semi-finished products of stainless steel
  • 7224 – Other alloy steel in ingots or other primary forms; semi-finished products of other alloy steel
  • 7205 – Granules and powders, of pig iron, spiegeleisen, iron or steel (if not covered under category pig iron)
  • 7208 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, hot-rolled, not clad, plated or coated
  • 7209 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, cold-rolled (cold-reduced), not clad, plated or coated
  • 7210 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, clad, plated or coated
  • 7211 – Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, not clad, plated or coated
  • 7212 – Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, clad, plated or coated
  • 7213 – Bars and rods, hot-rolled, in irregularly wound coils, of iron or non-alloy steel
  • 7214 – Other bars and rods of iron or non-alloy steel, not further worked than forged, hot-rolled, hot-drawn or hot-extruded, but including those twisted after rolling
  • 7215 – Other bars and rods of iron or non-alloy steel
  • 7216 – Angles, shapes and sections of iron or non-alloy steel
  • 7217 – Wire of iron or non-alloy steel
  • 7219 – Flat-rolled products of stainless steel, of a width of 600 mm or more
  • 7220 – Flat-rolled products of stainless steel, of a width of less than 600 mm
  • 7221 – Bars and rods, hot-rolled, in irregularly wound coils, of stainless steel
  • 7222 – Other bars and rods of stainless steel; angles, shapes and sections of stainless steel
  • 7223 – Wire of stainless steel
  • 7225 – Flat-rolled products of other alloy steel, of a width of 600 mm or more
  • 7226 – Flat-rolled products of other alloy steel, of a width of less than 600 mm
  • 7227 – Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel
  • 7228 – Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
  • 7229 – Wire of other alloy steel
  • 7301 – Sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel
  • 7302 – Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish- plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialised for jointing or fixing rails
  • 7303 – Tubes, pipes and hollow profiles, of cast iron
  • 7304 – Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel
  • 7305 – Other tubes and pipes (for example, welded, riveted or similarly closed), having circular cross-sections, the external diameter of which exceeds 406,4 mm, of iron or steel
  • 7306 – Other tubes, pipes and hollow profiles (for example, open seam or welded, riveted or similarly closed), of iron or steel
  • 7307 – Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel
  • 7308 – Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, lock- gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns), of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel
  • 7309 – Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7310 – Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7311 – Containers for compressed or liquefied gas, of iron or steel
  • 7318 – Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel
  • 7326 – Other articles of iron or steel

Which fertilizer product CN codes are included in EU CBAM?

Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.

  • 2808 00 00 – Nitric acid; sulphonitric acids
  • 3102 10 – Urea, whether or not in aqueous solution
  • 2814 – Ammonia, anhydrous or in aqueous solution
  • 2834 21 00 – Nitrates of potassium
  • 3102 – Mineral or chemical fertilisers, nitrogenous (except 3102 10 (Urea))
  • 3105 – Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus, and potassium; other fertilisers (except: 3105 60 00 – Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium)

Which electricity CN codes are included in EU CBAM?

  • 2716 00 00 – Electrical energy

Which cement product CN codes are included in EU CBAM?

  • 2507 00 80 – Other kaolinic clays
  • 2523 10 00 – Cement clinkers
  • 2523 21 00 – White Portland cement, whether or not artificially coloured
  • 2523 29 00 – Other Portland cement
  • 2523 90 00 – Other hydraulic cements
  • 2523 30 00 – Aluminous cement

Which chemical product CN codes are included in EU CBAM?

  • 2804 10 000 – Hydrogen

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