The European Commission published the EU’s 2027 Combined Nomenclature on 30 October, adding customs classifications for selected steel structures, aluminium scrap and industrial components. Issued under Commission Implementing Regulation (EU) 2026/2163, it applies from 1 January 2027 without itself expanding the legal scope of the Carbon Border Adjustment Mechanism (CBAM).
The Combined Nomenclature is the EU’s eight-digit product classification system, used for customs declarations, applicable tariff measures and detailed international trade statistics. The changes have practical implications for CBAM-covered metals, precursor accounting and the monitoring of imports from third countries, but a new customs code does not on its own create CBAM certificate obligations.
For wind energy components, new code 7308 90 53 identifies tubular steel monopile foundations and their sections used in wind turbines. The code falls within heading 7308, already relevant to the EU’s existing CBAM coverage of iron and steel articles, and distinguishes monopiles more precisely from other steel structures in customs records and trade statistics.
Steel fabricators exporting foundations and heavy structural components from outside the EU must review customs documentation, product descriptions and embedded-emissions records in response to the classification change. Exporters and European customers also need to reconcile their product classifications.
Aluminium waste and scrap receive new classifications under heading 7602. Code 7602 00 20 covers production waste and scrap, 7602 00 30 covers used beverage cans and 7602 00 40 covers used wheels. Other new classifications distinguish scrap by physical or chemical characteristics, including aluminium and silicon content, adding statistical detail to an industrial-material stream important to EU low-carbon metals supply chains. The classifications do not mean aluminium scrap automatically becomes subject to CBAM certificate obligations.
Code 7204 41 11 identifies certain ferrous waste containing a combined weight of at least 5% neodymium or praseodymium. It could provide more detailed visibility into scrap containing strategically important rare-earth materials, but customs classification alone does not determine its carbon-border treatment. Code 8503 00 30 separately identifies wind-turbine nacelle assemblies for supply-chain monitoring; it does not automatically place nacelles within the currently adopted CBAM product list.
Separate proposal would expand CBAM from 2028
The customs revision comes as the EU separately negotiates a proposal to extend CBAM to selected downstream steel and aluminium products. Legislative proposal COM(2025)989, under procedure 2025/0419(COD), envisages expanding coverage from 2028 and adding anti-circumvention measures. It has not become final law.
The European Parliament adopted amendments to the proposed expansion on 15 September 2026. Any eventual product coverage must be assessed against the adopted text rather than the Commission’s original proposal alone. The 2027 nomenclature is binding for customs classification from January 2027, while additional CBAM obligations remain subject to the legislative process.
Export coding and trade comparisons
Exporters and suppliers in Serbia, Montenegro, Bosnia and Herzegovina and Türkiye, along with other European industrial-supplier countries, need to reconcile export product codes with European customer classifications. They also need to distinguish products already covered by CBAM from those exposed only to the proposed expansion.
Steel-structure manufacturers, aluminium recyclers, industrial subcontractors and renewable-energy component suppliers may face additional documentation requirements even where their underlying emissions calculations do not change. Banks financing industrial exporters should review whether customer contracts, customs documentation and CBAM exposure models identify the same products consistently.
When an existing CN8 category is divided into new codes, apparent growth or decline in individual product categories may reflect reclassification rather than a change in physical trade. Import-share analysis must use the official correlation between the 2026 and 2027 classifications before comparing volumes, values and supplier-country market shares.
The immediate risk is not a new carbon charge created by the customs regulation, but inconsistent product classification, unreliable trade comparisons and incorrect assessments of current or future CBAM obligations.