Steel CBAM: one rejected
XML holds up every supplier.
Each non-EU mill must supply schema-valid emissions data. One rejected XML delays the entire declaration set.
What the XML must contain
Default-value exposure
What default values mean for a steel declaration.
Where a mill or re-roller cannot evidence actual embedded emissions, the declaration falls back to the default values published for the goods' country of origin. Those defaults carry a statutory mark-up of +10% in 2026, applied to the embedded emissions declared, not charged as a fixed fee.
Certificates are surrendered against the declared emissions after the free-allocation adjustment, which phases in from 2026. What that costs turns on the origin-specific default value for each CN code, the production route behind it, and the certificate price published for the quarter, currently €75.28 per tCO₂e for Q2 2026. Collecting actual supplier data removes the mark-up. Default emission values are origin-specific per the Annex to Regulation (EU) 2025/2621; CBAM scope per Annex I to Regulation (EU) 2023/956.
How Carbon Mandate solves it
One dashboard for every steel supplier on your declaration.
Frequently asked
Steel CBAM, answered.
Why is CBAM harder for steel importers than for other goods?
Steel is sourced from many mills and re-rollers across several origin countries, and each non-EU installation must supply schema-valid embedded-emissions data before the annual declaration can be filed. A single rejected or late XML from one supplier holds up the whole declaration set. The coordination load — not any one calculation — is the hard part.
What happens if a steel supplier cannot provide actual emissions data?
Where actual data is unavailable, the declaration falls back to default values, which carry a phased markup: +10% in 2026 under the default-value rules. On an illustrative crude-steel embedded factor of 1.850 tCO₂e per tonne, that uplift is paid in certificates. Collecting actual supplier data removes the markup.
Does Carbon Mandate file my CBAM declaration with the EU Registry?
No. Carbon Mandate is a preparer, not a filer. We check every incoming supplier XML against the EU CBAM schema, coordinate the supplier pipeline, and hand your filing team an audit-ready evidence pack. You remain the declarant of record and file with the EU Registry yourself.