The definitive CBAM changes European purchases of iron, steel and aluminium

The definitive CBAM regime has applied to covered imports since 1 January 2026. For suppliers of metals and semi-finished products, this mechanism provides a specific reason to reassess certain supplier bases without guaranteeing that they will be opened.

A permanent regime applicable since January 2026

The CBAM entered its definitive regime on 1 January 2026. It applies to European importers of covered iron, steel or aluminium products and components. Its application depends in particular on CN codes and the annual volume imported. The single mass threshold is set at 50 tonnes of CBAM goods per year.

The obligation is ongoing, with a price set each quarter in 2026. From 2027, this price must be set weekly. This change in frequency requires the importers concerned to monitor their exposure over time. It must be assessed at the level of the references actually purchased and imported.

Iron and steel account for most declared volumes

From 1 to 6 January 2026, iron and steel accounted for 98% of declared volumes covered by the CBAM. Western Europe was among the main importing regions over this period. This initial finding focuses commercial attention on European buyers with significant exposure to iron and steel products.

Companies to examine include importers, service centres and manufacturers purchasing covered steel or aluminium codes above the applicable threshold. Relevant contacts may include raw materials procurement directors, supply chain managers and metal category managers. However, exposure cannot be inferred solely from the company's industry.

Qualification must be conducted reference by reference

CN codes, the threshold, exemptions and options for technical substitution must be checked account by account. A company that purchases metal is not automatically covered by the scheme for all its product lines. Qualification must therefore begin by identifying the product purchased and its status under CBAM. It must also confirm that the relevant volumes exceed the applicable threshold.

The same work is required for machining companies, sheet metal companies, machine builders and component manufacturers using stocked references. In these companies, the relevant contacts may be the managing director, the raw materials purchasing manager or a senior procurement specialist. Their potential interest in a new source depends on the reference used, the openness of the supplier base and the supplier's civilian production capacity. Qualification by sector, material or programme alone is not enough to establish a commercial opportunity.

What this changes for suppliers

Steel or aluminium producers and semi-finished product manufacturers can target accounts whose purchases compete with covered imports. Service centres and stockists with regional availability can also assess these accounts. The starting point is not general communication about CBAM, but verification of the product reference purchased. We then recommend confirming the relevant volume and whether the supplier panel is genuinely open.

The commercial signal may be absorbed by suppliers that are already approved. Before any discussion, we therefore verify the reference, the supplier's civilian production capacity and whether the buyer can consider another source. This method avoids equating a regulatory constraint with an immediate intention to purchase. It allows us to focus prospecting on importers and industrial companies for which an offer involving steel, aluminium, semi-finished products or regional stock can genuinely be assessed.