Tools › Guides › Iron & steel articles (HS 73)
Exporting iron and steel articles — CBAM and embedded emissions
If you export steel-containing goods to Europe, the first technical question your customer will ask is no longer about price or lead time. It is about the embedded emissions of the goods you make.
Classification: chapter 72 versus chapter 73
- Chapter 72 covers iron and steel — primary and semi-finished forms, and the basic shapes.
- Chapter 73 covers articles of iron or steel: tubes, structures, fasteners, and so on.
- 7326 is the residual 'other articles' heading. It should only be used when no specific heading in chapter 73 fits. Classifying a named article into 7326 is one of the most common avoidable classification errors in this chapter — and, for CBAM, it can put you in the wrong scope entirely.
CBAM: your customer now needs data from you
The EU's Carbon Border Adjustment Mechanism covers iron and steel among other goods. EU importers must report embedded emissions for in-scope goods and, as the mechanism phases in, account for them financially.
What this means commercially: your EU buyer will ask you for the specific embedded emissions of the goods you produce, and increasingly for them to be verifiable. A supplier who cannot provide that data becomes a problem for the importer — which is a pricing and relationship issue long before it is a customs issue. Start collecting process-level energy and emissions data now.
CBAM's scope, methods and phase-in dates have been adjusted more than once. Verify the current position for your product and CN code rather than relying on a summary.
Other measures stack on top of the tariff
- Trade-defence measures. Anti-dumping, countervailing and safeguard measures have applied to a wide range of steel products in various markets, and the annexes of derivative products are amended periodically.
- US measures. Section 232 covers steel and aluminium and has been extended to a defined list of derivative products over time — check the current list, because 'my product is not steel' is not a safe assumption for a derived article.
- Preferential rates (where an agreement applies) are separate from all of the above and do not switch them off.
Documents
- Commercial invoice, packing list, transport document, certificate of origin.
- Mill test certificates for grade and chemistry — routinely required by buyers and by conformity regimes.
- The embedded-emissions data set for CBAM-exposed shipments, in the format the importer's reporting requires.
Use the tools
- HSN 7326 — other articles of iron or steel
- Market research — steel article import markets
- Exporting to the EU — VAT, CE, EUDR and CBAM
- How to find the right HS / HSN code
Sources & further reading
EU — Carbon Border Adjustment Mechanism Ministry of Steel, India WTO — trade defence
These guides summarise public material from the bodies named above. They are general information, not advice on a specific shipment, and they are not a substitute for a ruling from your customs authority or a qualified customs broker / consultant.
More guides
- How to find the right HS / HSN code for your export
- How to read trade data without fooling yourself
- How to estimate landed cost — FOB, CIF, duty and delivered
- The export document set: what is statutory and what is not
- Exporting to the UAE — classification, duty and documentation
- Exporting to the USA — HTS classification, entry and product gatekeepers
- Exporting to the EU — import VAT, CE marking, EUDR and CBAM
- Exporting to the UK — the UK Global Tariff, VAT and UKCA marking
- Exporting to Saudi Arabia — SABER, SFDA and GCC duty
- Exporting to Japan — CEPA preference, MHLW rules and residue limits
- Exporting to Australia — biosecurity, ECTA preference and FSANZ
- Exporting to the Netherlands — the EU gateway and how goods really enter
- Exporting to China — GACC registration, CCC marking and food rules
- Exporting to Germany — packaging law (LUCID), VAT and EU rules
- Exporting to Canada — bilingual labelling, CFIA and CBSA
- Exporting to Kenya — PVoC certification and KEBS standards
- Exporting to Nigeria — SONCAP, NAFDAC and Form M
- Exporting to Vietnam — AIFTA preference, Form AI and labelling
- Exporting to Indonesia — halal certification, SNI and import licensing
- Exporting to Turkey — the EU customs union, TAREKS and surveillance
- Exporting to South Africa — NRCS letters of authority and SACU duty
- Exporting to Brazil — RADAR, ANVISA, INMETRO and stacked taxes
- Exporting to Malaysia — AIFTA preference, JAKIM halal and SIRIM
- Exporting to the Philippines — AIFTA, FDA registration and ICC clearance
- Exporting to Sri Lanka — the ISFTA preference and its value-addition rule
- Exporting to Egypt — GOEIC factory registration and Arabic labelling
- Exporting to Chile — the PTA, SEC certification and warning labels
- Exporting to Tanzania — EAC duty, TBS conformity and TFDA
- Exporting to Mexico — NOM standards, the importers' registry and warning labels
- Exporting to Israel — the standard mark, Hebrew labelling and kosher
- Exporting to Bangladesh — SAFTA, BSTI and the letter-of-credit requirement
- Exporting to South Korea — CEPA, MFDS facility registration and the KC mark
- Exporting to Kuwait — KUCAS conformity and PAFN food rules
- Exporting to Thailand — AIFTA, TISI standards and Thai FDA registration
- Exporting to Switzerland — not the EU: customs, VAT and the EFTA agreement
- Exporting to Nepal — the India–Nepal treaty, not just SAFTA
- Exporting to Oman — conformity, food controls and logistics
- Exporting to Qatar — conformity, food controls and a high-income market
- Exporting to New Zealand — biosecurity, shared food standards and no agreement
- Exporting to Colombia — VUCE, INVIMA and ICA approvals
- Exporting to Kazakhstan — the EAEU customs union and EAC certification
- Exporting to Cambodia — AIFTA, import licensing and CamControl
- Exporting Indian tea (HS 0902) — grades, residues and market data
- Exporting basmati rice (HS 1006) — policy, residues and documents
- Exporting Indian spices (HS 0910) — curcumin, ETO and residues
- Exporting cotton yarn and textiles (HS 5205) — counts and traceability
- Exporting frozen shrimp and seafood (HS 0306) — listing and residues
- Exporting Indian coffee (HS 0901) — grades, OTA and EUDR
- Exporting leather and leather goods — REACH, EUDR and buyer audits
- Exporting fresh fruit (HS 08) — quarantine treatments and residues
- Exporting pharmaceuticals (HS 3004) — registration, GMP and the CPC
- Exporting gems and jewellery — Kimberley, hallmarking and provenance
- Exporting cashew (HS 0801) — origin, out-turn and residues
- Exporting ayurveda and herbal products (HS 1211) — novel food and heavy metals
- Exporting auto components (HS 8708) — IATF, homologation and origin
- Exporting jute and coir — anti-dumping, LDC competition and biosecurity
- Exporting groundnut (HS 1202) — aflatoxin and the EU health certificate
- Exporting buffalo meat (HS 0202) — plant approval and market access
- Exporting unmanufactured tobacco (HS 2401) — auctions, grades and TPD
- Exporting organic food — NPOP equivalence, and where it stops
- Exporting dairy products (HS 0402) — residue monitoring and market access
- Exporting onion (HS 0703) — the most policy-volatile export India has
- Exporting honey (HS 0409) — residues, the national plan and origin labelling
- Exporting cut flowers (HS 0603) — cold chain, auctions and plant health