CN 7209Covered by CBAMIron & Steel

CN 7209 under CBAM — Cold-Rolled Coils & Sheets

Flat-rolled products of iron or non-alloy steel, cold-rolled, width ≥ 600 mm, not clad, plated or coated

Cold-rolled (CR) coils and sheets — the tighter-tolerance, better-surface flat product that feeds automotive, white goods and precision fabrication. Indian CR exporters range from the integrated mills to standalone cold-rolling complexes buying HR coil as feedstock. For EU buyers, CR from India competes directly with EU mill supply, which makes the CBAM line item on your product highly visible.

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Covered

CBAM status of this heading

1 Jan 2026

Definitive phase — certificates due

€70–80

per tCO₂ — certificate price tracks EU ETS

up to ~40%

typical cost cut with verified actuals

Emission profile

Where the emissions in CN 7209 come from

A cold-rolling mill itself adds relatively modest energy, but the HR coil it consumes is a precursor — so a CR exporter’s embedded emissions are dominated by the upstream BF-BOF steelmaking. The EU default value for this heading is deliberately conservative — defaults are set high so that not filing actuals always costs more. Indian BF-BOF actuals typically land around 2.1–2.2 tCO₂/t of crude steel, while the defaults applied to Indian BF-route steel sit far higher, in the 3.5–5.0+ tCO₂/t range shown on our steel lander — a gap your buyer pays for until verified actuals close it.

Why we don’t print a default value here

The EU publishes and updates specific default values per goods category separately — quoting a stale number would mislead you. What never changes: defaults are set deliberately high, and the markup escalates from 10% in 2026 to 30% by 2028 for steel and aluminium (free-allowance phase-out runs to 2034). Use the CBAM calculator for a current, product-specific estimate.

What to do

Exporting under CN 7209? Three moves, in order.

01
Identify your production route and precursors
Trace your HR feedstock: own upstream mill or purchased coil? Purchased HR coil is a CBAM precursor, and the supplier’s installation-level emissions must flow into your CN 7209 figure.
02
Collect the data you already have
Cold-mill electricity bills, annealing-furnace fuel records, production logs, and — critically — the emissions documentation for your HR coil supply.
03
File verified actuals, not defaults
Have the numbers computed to the EU CBAM methodology and verified, then hand your EU buyer’s Authorised Declarant a filing they can use. Verified actuals typically cut the CBAM cost by up to ~40% versus default values — and the default markup only gets worse, escalating from 10% in 2026 to 30% by 2028 for steel and aluminium.

Free this quarter: We cover your first report (April–June 2026) so an inflated EU default never costs you an order. Continue only if you choose to. Free for the April–June 2026 quarter — start your report by 30 September 2026.

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Frequently asked

CN 7209 and CBAM, in plain English

Is CN 7209 covered by CBAM?

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Yes. CN 7209 — cold-rolled flat products of non-alloy steel 600 mm or wider — is a covered good under the EU Carbon Border Adjustment Mechanism. Any consignment under this heading imported into the EU has carried reporting obligations since the transitional phase (1 October 2023 – 31 December 2025), and since the definitive phase began on 1 January 2026 the EU importer must buy CBAM certificates against its embedded emissions. CR product carries the full embedded emissions of its hot-rolled precursor, so coverage effectively reaches back to the blast furnace.

How much CBAM cost does CN 7209 face in 2026?

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CBAM certificates track the EU ETS carbon price — roughly €70–80 per tonne of CO₂ in 2026 — so the bill is your embedded emissions multiplied by that price. For Indian BF-route steel products the difference between bases is dramatic: default-basis costs run roughly €250–270 per tonne of product, versus roughly €65–170 per tonne on verified actuals — about €80,000–€180,000 on a single 1,000-tonne consignment. The exact figure depends on your route and product mix, which is why the first step is a proper calculation, not a guess.

We only cold-roll — we don’t make steel. Why is our CBAM number so high?

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Because CBAM counts embedded emissions cradle-to-gate: the BF-BOF emissions inside your purchased HR coil travel with it as a precursor. Your rolling stage adds a comparatively small increment. The practical consequence is that your biggest CBAM lever is getting real, verified emission data from your HR supplier — something CarbonSettle handles as part of the supplier-chase step.

Is annealed or skin-passed CR still CN 7209?

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Yes — annealing, temper rolling and skin-passing do not move the product out of heading 7209 as long as it remains uncoated and 600 mm or wider. Once you galvanise, coat or paint it, it shifts to CN 7210, which is equally CBAM-covered.

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