Eurofer urges EU ferroalloys safeguard adoption

Eurofer has urged the European Commission to adopt its proposed tariff-rate quota (TRQ) safeguard on ferro-alloy imports, describing it as the “last chance” for the industry to recover after years of import pressure. The Commission issued its safeguard proposal last week following an investigation, with member states set to vote on Monday or Tuesday this week.

“There is no doubt that in the current critical situation, without any safeguard action this industry will disappear over the next years, creating a situation of total dependency for European users on supply from foreign countries,” Eurofer said last week.

The European steel industry, as a major consumer of ferro-alloys, has a strategic interest in maintaining upstream production capacity within the EU to ensure supply security and preserve the integrity of the European metals value chain, the association added.

The TRQ system proposed still allows limited yet significant import volumes to enter tariff-free, ensuring a fair balance between suppliers and users, according to Eurofer. “This action is not directed against any specific exporting country, but aims to strengthen EU economic resilience and autonomy,” it added.

The European Commission has proposed a three-year safeguard measure on imports of certain ferro-alloying elements effective from 18 November, following evidence of serious injury to Union producers, it said via a WTO notification seen by Kallanish.

The Commission concluded that the safeguard is in the Union’s strategic and economic interest, supporting the recovery of a sector vital to steelmaking, automotive, and advanced alloys, while maintaining a secure and stable supply for EU industries.

The measures are to apply to ferro-manganese, ferro-silicon, ferro-silico-manganese and ferro-silico-magnesium, under CN codes 7202 11, 7202 19, 7202 21, 7202 29, 7202 30 and 7202 99 30.

The Commission established product- and country-specific TRQs based on 2022-2024 average imports, distributed quarterly and increasing by 0.1% annually until expiry on 17 November 2028.

Major quota-holding origins under the safeguard include Norway – despite being an EEA member – India, South Africa, Malaysia, Kazakhstan, Brazil, China, and Zambia.

For ferro-manganese, Norway received 28,972 tonnes per quarter, India 17,626t, South Africa 8,273t, Malaysia 6,766t, South Korea 4,833t, and other suppliers 5,558t.

For ferro-silicon, Norway was granted 35,136t per quarter, Iceland 13,373t, Kazakhstan 8,090t, Brazil 6,316t, and other origins 24,984t.

For ferro-silico-manganese, Norway obtained 37,068t, India 31,959t, Zambia 7,882t, and other countries 18,956t.

For ferro-silico-magnesium, China was allocated 469t, Brazil 100t, India 7t, Thailand 77t, and other suppliers 19t.

In-quota imports enter duty-free, while out-of-quota volumes face a variable duty based on price thresholds of €1,316/t for ferro-manganese, €2,408/t for ferro-silicon, €1,392/t for ferro-silico-manganese, and €3,647/t for ferro-silico-magnesium.

The investigation covering 2019-mid-2025 revealed that EU ferro-alloy output halved, capacity utilisation fell to 35%, profitability dropped from +7% in 2021 to -20% in the latest period, and employment declined by nearly a quarter. Imports rose 13% in absolute terms and more than doubled relative to EU production, with import prices staying 5-17% below Union producers’ levels since 2021.

The Commission linked these trends to global overcapacity of around 27 million tonnes – about 16 times EU demand – combined with trade diversion following US duties on ferro-silicon from Brazil, Kazakhstan and Malaysia in 2025. These factors redirected large volumes to the EU market, intensifying price pressure and eroding profitability.

The measure excludes Ukraine and developing WTO members with import shares below 3% (collectively under 9%), as well as Algeria.

Elina Virchenko UAE

kallanish.com

 

European steel HRC prices steady; buyers doubt durability of rebound

European steel hot-rolled coil prices were little changed on Monday November 17, with offers firm, while buyers were warning that a recent rebound might be fragile amid lack of support from real demand, Fastmarkets heard.
Overall, offers for January-February-delivery HRC from integrated mills in the region varied between €620 and €650 ($719-753) per tonne ex-works, although workable prices tended to be lower amid limited trading, market sources said.

Market participants added that some mills were now largely booked-up until January or even February, which would allow them to maintain higher offer prices.

In Northern Europe, domestic HRC prices were estimated in the range of €600-620 per tonne ex-works by buyers, with some bookings reported at €605-615 per tonne in the Benelux area and Germany for January-delivery HRC.

Purchasing remained slow, with many buyers delaying new commitments because of the heavy inflow of imported tonnages expected to arrive in December and January.

“Some European mills still have some December tonnages to fill, but many buyers simply push decisions into January because of imports and unclear policy,” a buyer in the Benelux area said.

Fastmarkets’ daily steel hot-rolled coil index, domestic, exw Northern Europe, was €612.50 per tonne on Monday, down by just €0.42 per tonne from €612.92 per tonne on November 14.

The index was up by €2.50 per tonne week on week and by €21.25 per tonne month on month.

In Southern Europe, Fastmarkets’ daily steel hot-rolled coil index, domestic, exw Italy, was calculated at €600.00 per tonne on Monday, down by €1.25 per tonne from €601.25 per tonne on Friday.

The index was, however, up by €3.75 per tonne week on week and by €20.00 per tonne month on month.

Official offers from local suppliers for January delivery HRC were reported around €620 per tonne ex-works, but workable prices for January were closer to €600-610 er tonne ex-works, market sources said.

Some limited December-delivery tonnages were still available at €580–600 per tonne ex-works, depending on volume. Mills and rerollers were reported selling December tonnages around €590-595 per tonne, while continuing to quote €620 per tonne for 2026 delivery.

Market participants noted that activity in Italy remained very limited, with distributors and end-users still focused on destocking before year-end.

Import activity remained subdued across Europe, with many buyers hesitant to commit to new bookings before gaining clarity on landed costs, including Carbon Border Adjustment Mechanism (CBAM) charges.

Asian suppliers continued to offer material and some were reported willing to include CBAM costs to simplify transactions. Still, volumes remained limited because many buyers preferred to rely on port stocks to avoid logistical and administrative complications.

“Stocks are sufficient and everyone wants to see how the first CBAM declarations play out before making new commitments,” a buyer in Italy said.

Nonetheless, in October-November, European buyers booked significant tonnages of HRC from India, Indonesia, with arrival in 2026, Fastmarkets heard.

“Some suppliers are competitive even with CBAM,” a second buyer said.

Julia Bolotova

fastmarkets.com

EU draft sets out provisional CBAM benchmarks for steel; shows wide carbon-cost spread between steel routes

The European Commission is preparing to set provisional carbon emissions intensity benchmarks for iron and steel products under the Carbon Border Adjustment Mechanism (CBAM), according to a draft seen by Fastmarkets on Monday November 17.

The draft annex, circulated informally among industry stakeholders, outlines how “specific embedded free allocations” (SEFA) and “free allocation adjustments” (FAA) will be calculated once CBAM enters its full phase as of January 1 2026.

It provides the first detailed look at the benchmark emission factors that will determine the number of CBAM certificates importers must surrender and how those benchmarks align with existing EU Emissions Trading System (ETS) parameters.

For steel, the document sets three provisional benchmark values by production route — differentiating between blast furnace/basic oxygen furnace (BF/BOF), direct reduced iron/electric-arc furnace (DRI/EAF) and scrap-based EAF technologies.

These provisional benchmarks will underpin the FAA mechanism, effectively linking CBAM obligations to the phase-out of free allowances under the ETS. As free allocation amounts decline, importers of carbon-intensive steel will need to purchase more CBAM certificates to cover embedded emissions, calculated using the applicable benchmark.

While still marked “provisional,” the leaked document offers the clearest signal yet of how Brussels intends to operationalize CBAM’s FAA. The benchmarks are expected to be finalized in 2026, with phased updates for some products.

 

CBAM impact for flat steel

Under the draft CBAM free allocation annex, seen by Fastmarkets, steel hot-rolled coil carries benchmark values of 1.530 tCO2 per tonne for BF/BOF production, 1.033 tCO2 per tonne for DRI/EAF and 0.288 tCO2 per tonne for scrap-based EAF routes.

Based on these figures and a carbon permit price of around €80-90 ($92-104) per tonne of CO2, Fastmarkets estimates that CBAM-linked costs for imported HRC will range roughly between €40 and €120 per tonne of steel, depending on the production route, country of origin and any carbon costs already paid under domestic emissions schemes. For EAF-scrap-based steel, however, CBAM costs might be below €40 per tonne of steel, industry sources said.

For cold-rolled coil and hot-dipped galvanized coil, the draft shows slightly higher benchmark values [see table].

Sources told Fastmarkets that such benchmarks are “manageable” so far, considering the price gap between imports and domestic steel.

“Some suppliers in Asia offer HRC to Europe at prices over €100 per tonne below European,” a buyer in Italy said.

“These benchmarks can still be digested by the market,” a seller in Europe said.

Fastmarkets’ daily steel hot-rolled coil index domestic, exw Northern Europe was €612.92 per tonne on Friday November 14, up by €0.59 per tonne from €612.33 per tonne on Thursday November 13.

In contrast, Fastmarkets’ weekly price assessment for steel hot-rolled coil import, cfr main port Northern Europe was €480-520 per tonne on Wednesday November 12, widening downward from €485-520 per tonne the previous week.

Industry sources told Fastmarkets that the benchmark spread — more than 1.2 tonnes of CO2 per tonne of steel between BF/BOF and scrap-based routes — could sharply affect import competitiveness once the CBAM cost is fully priced at EU ETS levels.

“This reinforces the premium on low-carbon routes like EAF,” a steel trader in Germany said. “For producers relying on coal-based BF ironmaking, the adjustment could be brutal,” they added.

European steel buyers told Fastmarkets that uncertainty over benchmark levels and default-value publication has slowed trading activity for 2026 import deliveries. Several importers said they were unwilling to commit to import cargoes without knowing the precise CBAM component.

“Every tonne of steel entering the EU will carry a carbon cost — and Brussels is deciding what ‘best performance’ really means,” a buyer in Italy said. “But the market can’t stop and wait for the precise decision — so we keep operating in [a] very untransparent environment, unable to define the final price of the import cargo because the Commission didn’t provide timely instruments for that,” they added.

 

Different calculation routes

The draft regulation distinguishes between actual-data and default-value methods for determining each product’s SEFA.

Under the actual-data approach, operators must calculate benchmarks using the emissions intensity of each precursor material and the quantity of that precursor used in production — a process designed to capture site-specific performance.

The draft also confirms that recursive calculations will apply to complex goods, meaning precursor materials such as pig iron, crude steel and ferro-alloys are included in the total embedded emissions of the final product.

In CBAM terminology, a precursor is any input material (or intermediate product) that is used to produce another good — and that itself has a benchmark value for its embedded emissions.

For example, for HDG coil, there are several precursors required:
Cold-rolled coil — precursor to galvanized coil
Hot-rolled coil — precursor to CRC
Hot metal or pig iron — precursor to HRC
Coke, sinter, pellets — precursors to hot metal
Each of those stages has its own benchmark.

So, if a producer reports actual data, they would calculate the SEFA for galvanized coil by multiplying the benchmark value of each precursor by the amount of that precursor used — then adding the emissions from any additional on-site processing (like galvanizing).

By contrast, users of default values apply standardized Commission benchmarks directly, simplifying reporting but offering less precision and likely paying higher CBAM certificate costs, since default values will generally be set above verified emissions levels.

If a non-EU producer cannot provide verified emission data, the CBAM regulation allows using default emission factors, published by the European Commission — based on benchmark values or worst-case averages.

Default values pending

Default values represent average embedded-emission intensities for each product and production route. They apply whenever verified actual data are unavailable, allowing importers to complete CBAM declarations even without detailed upstream information.

According to industry sources, the final set of default values will be published in early 2026, together with the final ETS benchmarks. Until then, market participants face uncertainty over the exact emission factors that will determine CBAM certificate obligations and import competitiveness.

A source familiar with the matter told Fastmarkets that finalized default values and benchmarks will likely be published only in March/April 2026.

Shyamal Patel in London contributed to this story

Julia Bolotova

fastmarkets.com

Polish long steel prices remain flat amid weak construction sector

Polish steel rebar and wire rod prices were unchanged during the week to Friday November 14, with muted demand from key sectors impacting the market, sources said.

“It’s not a good time for the construction industry,” one trader source told Fastmarkets, adding that demand for properties in Poland remains affected by high interest rates.

Other sources said demand volumes remained stable, with no significant change observed in the market.

During the week to Friday, estimations of workable levels for wire rod were heard around 2,580-2,650 zloty ($706.73-725.90) per tonne CPT, the same as in the previous assessment period.

Fastmarkets’ weekly price assessment for steel wire rod (drawing quality), domestic, delivered Poland was 2,580-2,650 zloty per tonne, unchanged week on week.

Polish rebar prices were also stable in the week to Friday.

Estimations of workable levels were heard at 2,420-2,450 zloty per tonne CPT, stable form the previous week.

Fastmarkets’ weekly price assessment for steel reinforcing bar (rebar), domestic, cpt Poland was 2,420-2,450 zloty per tonne, unchanged week on week.

Davide Montagner

fastmarkets.com

OECD: EU steel demand expected to see gradual recovery from 2026

SteelOrbis talked to Luciano Giua, economist and policy analyst at the Organization for OECD, regarding the latest developments in EU steel market.

How would you describe the current steel demand trends in the EU steel market across major sectors (construction, automotive, machinery, etc.)?

Demand remains weak across most major EU economies, reflecting subdued construction activity, lower automotive output and soft manufacturing orders. Germany, France and Spain are contracting, while Italy shows modest resilience linked to construction demand.

How are high energy prices affecting output, investment and competitiveness?

High electricity and gas prices continue to weigh on production, margins and investment capacity. Compared with MENA producers, who benefit from subsidised energy, EU mills face a clear cost disadvantage that erodes competitiveness.

What are the effects of geopolitical developments on trade routes?

In the EU, stricter safeguard measures and the rollout of CBAM have tightened import conditions and supported prices, even as weak demand and high costs weigh on the sector. Globally, Chinese exports are reshaping trade routes, with flows increasingly redirected toward less protected markets in Asia, Africa and Latin America.

What are your expectations for steel demand and prices in the short to medium term?

EU steel demand is expected to remain weak through 2025 but stabilise as conditions improve, with a gradual recovery anticipated from 2026 driven by infrastructure and defence spending.

Are you optimistic or cautious about the EU steel sector’s medium-term competitiveness?

Cautious. Falling profitability, high energy and borrowing costs, and limited investment capacity all weigh on medium-term competitiveness despite some regional improvements.

How do you see the balance between environmental targets and global competitiveness?

Our recent analysis suggests this remains a challenge: persistent cost pressures and tight margins risk slowing investment in decarbonisation, while producers in regions with subsidised energy retain a competitive edge.

steelorbis.com

France’s Vallourec posts lower Jan-Sept sales revenue amid weaker tube segment

France-based pipe manufacturer Vallourec has announced its financial results for the third quarter and the first nine months this year.

In the third quarter this year, Vallourec’s sales revenue increased by 1.9 percent year on year to €911 million, while it reported an EBITDA of €210 million, compared to €168 million in the third quarter last year. In the first nine months this year, the company’s sales revenue totaled €2.77 billion, down by 6.8 percent year on year, driven by lower volumes and average selling prices in the tube segment, while its EBITDA was €604 million, compared to €618 million in the same period last year.

The company’s sales volume increased by 3.8 percent year on year to 303,000 mt in the third quarter of the year, while the January-September sales volume amounted to 909,000 mt, down 2.8 percent year on year.

The company expects an EBITDA in the range of €799-829 million for the full year.

steelorbis.com

Tata Steel Nederland to acquire Vattenfall power plants to support green steel transition

Tata Steel Nederland has taken a major step toward its long-term decarbonisation strategy by signing a definitive agreement to acquire three Vattenfall power plants in the IJmond region of the Netherlands. The assets, which currently run on residual steelmaking gases, will be transferred to Tata Steel Nederland on January 1, 2026.
Although financial details of the agreement have not been disclosed, the transfer has received full approval from relevant authorities, including the Netherlands Authority for Consumers and Markets (ACM).

A strategic acquisition to support low-carbon steel production

Tata Steel Nederland CEO Hans van den Berg described the ownership transfer as a significant step in the company’s green steel roadmap. Direct ownership of the power units will allow the company to orchestrate a controlled shift from traditional steelmaking to cleaner production pathways.

The Vattenfall power plants in the IJmond region consist of three units. Power plants 24 and 25 in Velsen-Noord generate electricity primarily from residual gases produced during steelmaking, and this electricity is used by Tate Steel Nederland in its operations. The third unit, IJmond 01, is a combined heat and power plant located on the Tata Steel site in IJmuiden. It is also fueled by steel production gases and produces both electricity and steam, which are used in the steelmaker’s processes.

steelorbis.com

EU proposes TRQ to reduce ferro-alloy imports by 25 percent

Following a safeguard investigation initiated in December 2024 regarding six alloying elements, namely, silicon, ferromanganese, ferrosilicon, ferrosilicomanganese, ferrosilicomagnesium and calcium-silicon, the European Commission has announced a proposed safeguard measure aimed at cutting imports of some silicon and manganese-based ferroalloys (namely, ferromanganese, ferrosilicon, ferrosilicomanganese and ferrosilicomagnesium) into the EU by 25 percent compared with average inflows during 2022-24.

This level is calculated taking into account a sustainable market share (30-40 percent) that would allow the EU industry to recover from the injurious situation, while maintaining adequate sources of supply for downstream users.

Under the proposed measure, which is set to take effect on November 18, 2025, and run through November 17, 2028, product-specific tariff-rate quotas (TRQs) will be allocated by product and country. Imports within the quota will enter duty-free, while volumes above the quota will be subject to duty.

The European association of ferroalloys and silicon producers Euroalliages has urged EU member states to support the proposed measures, stating, “Without these safeguards, the European ferroalloy industry will not exist in five years.”

In addition, according to a statement released by Assofermet, the association representing Italian distributors of steel and scrap, “The reduction in available import tonnages, if confirmed at 25 percent, will inevitably create distortions and difficulties in the market, as EU production of ferroalloys has been insufficient to meet domestic demand for years.” Assofermet has asked the European Union to:

reduce import volumes by 20 percent, not 25 percent,
introduce a carry-over mechanism,
apply a liberalization rate of two percent instead of one percent.
The association’s biggest concern relates to the imposition of variable duties, which will only be calculated at the time of customs clearance and will therefore be impossible to include in the actual price of negotiations. Finally, the association notes that the safeguard also includes Norway and Iceland, two countries that, as members of the EEA (European Economic Area), have always been excluded from measures relating to steel imports. In particular, limiting trade with Norway, of which the EU is the main partner, would compromise political relations and the overall balance. Therefore, Assofermet said, the issue goes beyond the scope of safeguards, concerning the possibility of “contemplating economic prospects of greater relevance and scope.”

steelorbis.com

Missing uniform standard hampers low-emission market development

The market for premium low-emission steel has been slow to develop due mainly to there not being a clear, uniform standard to define this material. This needs to be implemented preferably without government regulation, speakers said at last week’s Kallanish Green Steel Strategies in Brussels.

It is pointless to estimate the level of “green premium” without first having this standard. “Instead of talking about a green premium, first, let’s talk about making sure we know what is the level of decarbonisation. The way we measure it, we have a clear methodology, and then after that, I think everything will fall into place,” said Gilles Mirol, chief marketing officer at Hydnum Steel.

“I think standards are important as well … I don’t think today the green still demand is what it is because of the lack of the standards. So it definitely helps in scaling up the demand and also having … uniformity and how we define it, especially in the green budget procurement,” noted SSAB Europe head of business innovation, market intelligence, and sustainability Madhu Sayeenathan. “That’s where we need some sort of European Union level definition or sort of labelling system, which is part of the … Steel and Metals Action Plan.”

Product footprint transparency is doubly important when selling with a low-emission premium to the private sector. “If you’re talking with private customers, then you absolutely need to have transparency in your pricing. Bottom line conclusion is that you cannot defend, let’s say, an additional surcharge of a couple of hundred of euros [without providing the product’s entire environmental footprint],” said Royal Bam Group category manager steel Werner Wijne.

“If it really comes to purchasing green steel, then it’s always a discussion about the cost,” commented LESS aisbl secretary general Carmen Ostwald. “This is also not easy for the steel consuming companies, because they also need the end consumers to pay for the price premium of green steel. And so far, we must really see that there is no willingness by the end consumers to pay for this – only in small, niche markets.”

“From my point of view, it’s very good that the European Commission is discussing a carbon intensity label for steel now, which shall start as a voluntary label, but I think in the midterm, it’s also very important that this will become a mandatory label,” she added.

However, a green steel standard should not be overregulated by government. “I don’t think we should have a government regulation. I think the standard should be like the referee of the green steel market,” said Mirol. Low-emission and “Made in Europe” public procurement mandates are where the government could help, however, he added.

Using more scrap is meanwhile not the only answer for decarbonisation, as steel is already highly recycled and scrap supply will become scarcer in future. Primary steel production also needs incentives to decarbonise, while existing scrap-based steelmakers can still take steps to lower emissions by switching to renewable energy sources, Ostwald noted.

The importance of offtake agreements was acknowledged. “It gives us a signal. It shows us the interest from the customers,” said Sayeenathan. These agreements “give security to the investors that, coming into the project, that there is a demand in various sectors,” added Mirol.

On producing all steel grades using an EAF, Mirol noted: “Of course, you start with the easy stuff … drawing grades, structural grades, using quite a high level of scrap. And slowly but surely, you move yourself up in difficulties, in grades and thickness, in format, in the end users and having more green OBM [ore-based metallic] into it … And the commercial agreements we discuss with customers are based on that.”

Sayeenathan added: “I think some customers, they want all of that to be turned into the low-emission steel operating now … We are already producing in our Americas [division] through the electrical furnace, and then we are paying a lot of knowledge on how to produce even the advanced steel grades for the automotive. So then with that, we can ramp up quite fast, but it’s more about managing the expectation from the customers in terms of the volumes.”

Adam Smith Austria

kallanish.com

 

Provisional CBAM benchmarks show high costs on defaults

Long-anticipated draft provisional benchmarks for the Carbon Border Adjustment Mechanism (CBAM), seen by McCloskey late last week, potentially entail higher-than-expected costs for importers when calculating on default values.
The draft legislation and accompanying annex detail rules, formulae, and provisional benchmark values for the adjustment of CBAM emissions liabilities. Deductions are made in line with what free emissions allowances third country installations would be entitled to if operating under the EU Emissions Trading System (ETS) – the so-called Free Allocations Adjustment (FAA).
While calculating the FAA deductible from CBAM declarations using actual values requires detailed, verified production data, and yet-unseen implementing acts on both embedded emissions calculations and methodology, McCloskey has sourced a spreadsheet detailing provisional country-specific default values at the product level. Using these default values in combination with the drafts should allow importers to calculate their specific worst-case CBAM exposure with much greater certainty.

The Free Allocations Adjustment (FAA)

As detailed in an earlier article, CBAM imposes costs on emissions embedded in imports from third country productions, whereas the EU Emissions Trading System (ETS) manages emissions at the process level. Free allocations under the ETS are awarded on the basis of a domestic installation’s historic production rate, benchmark-adjusted to its top 10% best-performing equivalents within a product sector during a prior reference period.
In order to maintain the equivalence between ETS free allowances and CBAM liabilities for WTO-compliance, these ‘ETS benchmarks’ must be combined or transposed into ‘CBAM benchmarks’ at the product level, ensuring that cost obligations for both systems are operating on common factors as far as possible.
Both the ETS free allocation formula, and CBAM emissions liabilities are also subject to the same ‘CBAM factor,’ which starts at 97.5% from 2026 and reduces at an increasing rate until it hits 0% in 2034 – reducing free allocations to zero and making importers fully liable for embedded emissions.
The draft regulation on FAA calculation details the mechanisms behind this equivalence principle, seeking to maintain consistency not only in terms of cost benchmarking, but also as relates to data quality. Effectively, distinct CBAM benchmarks are to be referenced, depending on whether calculating on actual or default emissions.
Deriving the FAA to be deducted requires calculations as to the ‘specific embedded free allocations’ (SEFA) that a single ton of the import would have received as a result of its production process under the EU ETS. For declarations on actual values, said calculation must also be repeated recursively for each of the import’s constituent precursors in relation to relevant CBAM product-level benchmarks, specific to the processing stage, with the results combined into a total SEFA for the final imported good. For default values, specific all-in ‘default benchmarks’ allow calculation of the FAA in a single stage.

SEFA = CBAM factor x CBAM benchmark x Cross-Sectoral Correction Factor*
CBAM certificates = Total Embedded Emissions – Free Allocation Adjustment – Carbon Price Already Paid

*(The CSCF reduces free allocation across the ETS where demand exceeds supply. CSCF 2021-2025 = 1)

Multiplying the SEFA by the total mass of the imported goods gives the FAA, which is then deducted from the total embedded emissions to derive the number of CBAM certificates that must be surrendered, prior to further deductions for carbon prices already paid (t CO2e).
Total embedded emissions require verification when using actual values, with CBAM goods assumed by default to have been produced in the same year as the reporting period unless sufficiently evidenced otherwise. The draft defines this reporting period as 2026 at the earliest for both product and precursor emissions, meaning even Q1 2026 imports produced in 2025 will be assessed on the basis of physically verified 2026 levels to patch frictions between the transitional and definitive stages.

Provisional CBAM benchmarks, actual and default

The annex to the draft FAA regulation lists the provisional CBAM benchmark values required to make CBAM calculations, which are based on the current 2021-2025 ETS benchmarks. Notably the draft provisional benchmarks have been adjusted to projected revisions to be made to the underlying ETS benchmarks later in 2026, and are thus less likely to change prior to adoption than was previously suspected on benchmark update
timelines.

Due to the flexibility required in adapting ETS benchmarks to CBAM in assessing emissions at the border, there is no single catch-all CBAM benchmark value for a steel product, with relevant steel benchmarks instead divided by data quality, and production route.
Provisional benchmarks in the drafts are available at the product code level for CBAM’s covered goods, and are presented in two columns: the benchmarks in column A are limited to the specific process emissions for the production of the good and are to be mirrored to specific third country production processes when performing recursive actual values calculations, with simplified all-in product-level benchmarks for default values
calculations in column B.
When making CBAM declarations on actual emissions values, detailed information is required on the production processes of third-country producers in order to accurately map their specific production processes and product characteristics to the corresponding ETS benchmarks.

The draft annex dictates the rules on which production-route specific column A benchmark to adopt when using actual values:

  • Scrap-EAF: “more than [50%] of mass of the crude steel produced or used is sourced from scrap.”
  • DRI-EAF: “more than [50%] of mass of the crude steel produced or used is sourced from DRI.”
  • BF-BOF: “more than [50%] of mass of the crude steel produced or used is sourced from a blast furnace or smelting reduction route.”
  • “If neither of the three routes above contribute more than [50%] of the final steel, the production route is selected based on the component contributing the highest mass of the steel.“

Provisional CBAM benchmarks, default values

Column B’s ‘default CBAM benchmarks’ are only for use when making declarations on default values, making various assumptions in terms of the goods composition – such as steel alloy content – and are designed to be applicable across different origins. These benchmarks are then further split by process route, with separate benchmarks for scrap to electric-arc furnace (scrap-EAF); natural gas-based direct-reduced iron to EAF (DRI-
EAF); and blast furnace to basic oxygen furnace (BF-BOF) productions.
Yet unreleased draft implementing acts on methodology and embedded emissions calculations will further clarify which of these production route-specific default CBAM benchmarks are to be used – depending on product and precursor origin – to maintain methodological and data consistency between the default benchmarks and default emissions values for each country.

Provisional default values – contained in a separate file – are split by origin; product code; and direct and indirect emissions; and continue to be relatively elevated as a punitive measure to incentivize declarations on actual values. CBAM-liability for the definitive stage is currently limited to direct embedded emissions.
For example – assuming a CBAM certificate price of EUR80 – CBAM costs for an import of Indian-origin BF-BOF hot-rolled coil (HRC) would theoretically be calculated in reference to a default specific embedded emissions value of 4.27t CO2e/t, and a default benchmark value of 1.53t CO2e/t, giving a result of around EUR220/t.
Scrap-EAF Turkish-origin HRC – which has been booked by multiple service centers due to competitive EPDs of around 0.9t CO2e/t – when calculated on default values and benchmarks could see a CBAM liability of around EUR140/t.
Further examples are detailed in the table at the bottom of this article – it is important to remember that the specific production-route default benchmark value to be used is yet to be clarified by the Commission, with default routes for each origin to be set consistent with the methodology used to calculate the default emissions values.

Closing a DRI loophole

The draft regulation and annex make specific reference to natural gas-based DRI, explaining the need for DRI-specific benchmarks both for independent import, and as a precursor in EAF steelmaking.
DRI is currently included in the ETS hot metal benchmark, but was excluded from the benchmark update calculation for 2026-2030 to avoid artificially cutting the ETS benchmark for blast-furnace producers.
As such, if DRI-based steel was allowed to enter the EU on a CBAM benchmark tied to the ETS’ hot metal benchmark, it would receive an FAA in excess of its embedded emissions, negating any CBAM obligation for DRI-based imports and even making them more competitive than scrap-EAF based imports, which have their own underlying ETS benchmark reference.
To avoid this, separate actual and default benchmark values were created for DRI imports, and steel CBAM benchmarks have an intermediary value for DRI-EAF, “ensur[ing] that the reduction of the CBAM certificates to be surrendered stemming from the free allocation adjustment for primary natural gas-based DRI imports is higher than for primary blast furnace steel, but lower than for secondary steel.”
When calculating on actual emissions values, DRI has a provisional process-stage specific CBAM benchmark of 0.5t CO2e/t, and a default benchmark value of 0.723t CO2e/t.
Overall, the Commission’s drafts give a lot more clarity to the trade in terms of the worst-case additional costs when importing steel – and submitting CBAM declarations – on default values. Costs stemming from default value declarations will be very high if default benchmarks and values are implemented in their current form, incentivising either the use of complex actual values calculations, or tactical circumventions.

Benjamin Steven  Journalist, Steel

opisnet.com