Reliable assessment of imports covered by the European Union’s Carbon Border Adjustment Mechanism (CBAM) requires analysis by eight-digit Combined Nomenclature (CN) code. The 2025 aggregate for goods specified in Annex I of the CBAM Regulation was €111.23 billion, but customs chapters can contain products that are not covered. Treating every product in a broad chapter as subject to a carbon-border charge can therefore misrepresent the trade exposed.
Rankings need to compare the same geography, year, trade flow and classification. The largest structural categories include iron and steel products, primary aluminium, semi-finished metal products, electricity, fertilisers and clinker. Yet values for individual products can differ sharply: EU extra-EU imports of unwrought non-alloyed aluminium under CN code 7601 10 90 were about €7.51 billion in 2025. A reported value for a specific flow of hot-rolled steel from Türkiye, for example, cannot be treated as the EU-wide total for that customs code.
Classification also matters for emissions assessment. Primary metal, billets, sheets, tubes, profiles and fasteners can have different embedded-emissions boundaries and process requirements. For fertilisers, distinguishing urea from other nitrogen products affects which processes and precursors must be assessed. Electricity, classified under CN 2716 00 00, requires a separate evidence chain involving grid scheduling, metering and emission factors, and direct power-purchase contracts where applicable.
Correct coding can affect whether an importer crosses the 50-tonne annual de minimis threshold for the four mass-based sectors. Electricity and hydrogen are not eligible for that exemption. Companies need to reconcile product master data and customs declarations with CBAM records before calculating emissions or certificates. Incorrect codes can create liability, delay release for free circulation or distort management forecasts.
A complete CN8 intelligence table should include product descriptions, annual and quarterly values, net mass, non-EU origin, the reporting EU member state, named installations where known, main industrial processors and downstream end uses. It should also flag exempt origins and pending legislative amendments. This product-level information is the basis for meaningful rankings of importers and final beneficiaries; efforts to identify those companies using aggregated customs figures alone remain provisional.