All CBAM CN codes
CN 7228Covered by CBAMIron & Steel

CN 7228 under CBAM — Alloy Steel Bars & Sections

Other bars and rods of other alloy steel; angles, shapes and sections of other alloy steel

Alloy steel bars and sections — the forging-grade, spring, bearing and chrome-moly bars that feed Europe’s automotive and engineering supply chains. The Durgapur–Jamshedpur alloy belt and Pune–Ludhiana component ecosystems export heavily under this heading, often as certified grades on long-term OEM programmes where a missing CBAM data trail now threatens the programme itself.

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 7228 come from

Alloy long products in India come off electric melting (EAF or induction, grid-dependent) as well as BF-BOF at integrated plants, with ferro-alloys as emission-relevant precursors. Defaults compress that spread into one conservative number. The EU default value for this heading is deliberately conservative; an OEM-audited plant with clean energy records usually beats it — on verified actuals.

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 7228? Three moves, in order.

  1. 01

    Identify your production route and precursors

    Identify the melt route and the alloying inputs — ferro-alloys are precursors — and whether feedstock billet is produced in-house or purchased.

  2. 02

    Collect the data you already have

    Furnace electricity and fuel records, ferro-alloy purchase data, billet sourcing documents, heat-treatment logs, production records — largely the same evidence your OEM quality audits already demand.

  3. 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 7228 and CBAM, in plain English

Is CN 7228 covered by CBAM?

Yes. CN 7228 — bars, rods and sections of other alloy steel — 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. Forging-grade and engineering-alloy bars destined for EU automotive and machinery makers fall here.

How much CBAM cost does CN 7228 face in 2026?

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.

Our EU OEM customer is asking for CBAM data directly. Is that normal?

Yes, and increasingly standard. The legal obligation sits with the EU importer’s Authorised Declarant, but the data can only come from your installation — so OEMs and their declarants push the request upstream to you. Suppliers who respond with a verified, methodology-correct filing become easier to keep; suppliers who can’t force their buyer onto expensive defaults. Treat the data request as a commercial retention issue, not paperwork.

Forged components made from our alloy bar — covered too?

Articles forged from steel generally fall under Chapter 73 headings such as CN 7326, which are CBAM-covered, with your bar counted as a precursor. So the emission data you establish for CN 7228 flows straight into your forging customers’ filings — one more reason bar-stage verified actuals make you a stickier supplier.