US EAF-dominant steel production carries low default values — many US exporters may face near-zero certificate liability.
US steel exports to the EU include flat-rolled products, seamless pipes, and speciality alloy steels. The USA's steel default (1.39 tCO₂e/t semi-finished, BF-BOF) is among the lowest globally — reflecting the US industry's predominantly EAF-scrap-based production mix. Primary and secondary aluminium products are exported to EU markets for aerospace and automotive applications.
Source: IR (EU) 2026/1740 Annex I, which replaced the Annex I of IR (EU) 2025/2621 from 1 January 2026 · Default = the published total-emissions value · Net cost adds the Annex I mark-up once — 10% in 2026 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, 1% for fertilisers · Used when verified actual data is not provided
| Product | Sector | Default tCO₂e/t | Net cost 2026 €/t | Net cost 2030 €/t |
|---|---|---|---|---|
Grey Portland cement CN 25232900 | Cement | 1.2100 | €97.69 | €60.98 |
Anhydrous ammonia CN 28141000 | Fertilisers | 3.4100 | €252.79 | €133.53 |
Urea (solid) CN 31021019 | Fertilisers | 2.2900 | €169.76 | €89.67 |
Ammonium nitrate CN 31023090 | Fertilisers | 2.2700 | €168.28 | €88.89 |
Steel semi-finished (BF-BOF) CN 72071114 | Iron & Steel | 1.3900 | €112.23 | €70.06 |
Unwrought aluminium CN 7601 | Aluminium | 1.7000 | €137.25 | €85.68 |
Hydrogen CN 28041000 | Hydrogen | 26.6400 | €2150.85 | €1342.65 |
Net cost = default tCO₂e/t × €75.28 (Q2 2026, official price of CBAM certificates) × CBAM phase-in factor (2.5% in 2026, 48.5% in 2030). Actual liability depends on verified embedded emissions and SEFA benchmark deduction. Values shown are for illustrative default scenario only.
Carbon pricing in USA: The USA has no federal carbon pricing scheme. State-level cap-and-trade systems (California, RGGI) do not cover industrial CBAM-relevant production at a scale or price that would qualify for Article 9.
There is no federal carbon price in the United States. California's programme and RGGI do not reach CBAM-covered industrial production, so no price is effectively paid on these goods and there is nothing to deduct.
Our reading of USA's own published measures as at September 2026, not an EU-published value — third-country carbon policy changes without warning. Confirm the current position with advisers in the country of production before pricing anything on it.
US EAF steel carries actual embedded emissions typically in the 0.3–0.6 tCO₂e/t range, well below the country default an unverified exporter is assigned. Verification is therefore high-value: a verifier engagement usually costs far less than paying default-based certificates on clean production. It will not normally take the liability to zero, however — a scrap/EAF good is measured against the route (E) benchmark of 0.066 tCO₂e/t [IR (EU) 2025/2620 Annex point 5, Column B], which sits below that actual range, so a chargeable gap remains.
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Book a demoDefault values sourced from IR (EU) 2026/1740 Annex I (European Commission). Net costs are illustrative — actual liability depends on verified embedded emissions, SEFA benchmark deduction, and the applicable CBAM phase-in factor. Not legal or compliance advice.
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