Germany accounted for 12.7% of the EU’s extra-EU imports of goods under existing Carbon Border Adjustment Mechanism (CBAM) codes in 2025, equivalent to around 14.1 billion euros, based on a rounded calculation using Eurostat country shares. The scale of that demand matters for metal suppliers because imported steel and aluminium can pass through several businesses before reaching automotive, machinery and infrastructure supply chains.
A vehicle manufacturer may buy pressings, castings, structural parts and subassemblies from tier-one or tier-two suppliers instead of purchasing the originating metal. Those suppliers may source sheets and profiles from processors using both imported and domestically produced feedstock, with each commercial stage having its own contracts, inventory policies and access to emissions records.
Consequently, the entity expected to surrender CBAM certificates may lack the bargaining power to pass the full cost down the chain. Imported material with low emissions and credible installation data may also compare differently under CBAM with high-emissions products assessed using default values. For manufacturers, gaps in evidence can add cost and delivery uncertainty in a supply base where the origin and emissions data for materials may be less transparent.
Processors and market conditions
The European Steel Association reported weak demand, low capacity utilisation and continued pressure on exports in 2026. Those conditions indicate that carbon policy is only one part of a difficult steel-market environment. EU producers also face energy, wage and capital costs, while the gradual phase-out of free allowances under the EU Emissions Trading System (EU ETS) changes their exposure.
Novelis manufactures and recycles aluminium products for automotive and packaging markets at its German operation in Nachterstedt. Klöckner & Co operates a network of metal-processing and service-centre businesses. These examples show the relevance of intermediate processors, but do not establish the origin of every tonne supplied to a vehicle maker.
A German CBAM study could combine CN8 import values with metal-processing locations, component procurement and the identities of actual buyers where public documentation supports a link. It could also test whether contracts explicitly separate raw-material prices from carbon adjustments, areas relevant to assessing where costs and emissions evidence sit across supply chains.