Is your product covered by CBAM? How to read the Annex I list by CN code

By Ahmed Medhat · Published11 October 2026

Whether a product is covered by CBAM comes down to one check: does its CN code fall under an entry in Annex I to Regulation (EU) 2023/956? The list is short, but it is written at four different levels, with exceptions, and one entry covers only part of its code. Here is how to read it.

The list is written in CN codes

Annex I, point 1, says the Regulation applies "to goods falling under the Combined Nomenclature ('CN') codes set out in the following table", and that "The CN codes shall be those under Regulation (EEC) No 2658/87." So the reference is the good's code in the Combined Nomenclature set by Regulation (EEC) No 2658/87.

That code belongs to the good. It follows from what the good is, under the rules of the Combined Nomenclature. It is not something to pick in order to bring a good into CBAM or keep it out.

Four levels of entry

An entry covers the goods "falling under" it, so a short code covers every longer code beneath it. Annex I's main entries come in four lengths (inside the chapter 72 Except list there is also one five-digit code, 7202 2):

• A whole chapter. "72 – Iron and steel" covers chapter 72, apart from the exceptions listed under it.
• A four-digit heading. "7318 – Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel" covers every code under 7318. So do "3102 – Mineral or chemical fertilisers, nitrogenous" and "7601 – Unwrought aluminium".
• A six-digit subheading. "7303 00 – Tubes, pipes and hollow profiles, of cast iron".
• A full eight-digit code. "2523 10 00 – Cement clinkers", "2716 00 00 – Electrical energy", "2804 10 00 – Hydrogen".

Exceptions, and one "ex" entry

Some entries carry an "Except" list. Chapter 72 is covered except the ferro-alloys listed under it, such as "7202 2 – Ferro-silicon" and "7202 30 00 – Ferro-silico-manganese", and except "7204 – Ferrous waste and scrap; remelting scrap ingots and steel". Heading 3105 is covered except "3105 60 00 – Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium".

One cement entry is marked "ex": "ex 2507 00 80 – Other kaolinic clays except non-calcined kaolinic clays". The "ex" means only part of code 2507 00 80 is covered, the part the description names. Non-calcined kaolinic clays under that code are not.

Where the list stops

The list has gaps worth knowing, all visible in the adopted text:

• Chapter 73 is listed heading by heading, not as a whole. It includes 7301 to 7311, 7318 and 7326. Headings such as 7312, 7313, 7314, 7315, 7316, 7317 and 7319 to 7325 are not on it.
• Aluminium is listed heading by heading too. It runs from 7601 to 7616, but 7602 and 7615 are not on it.
• Only these chapters appear at all: 25, 26 (one code, 2601 12 00), 27, 28, 31, 72, 73 and 76. A good classified in any other chapter is not in Annex I, even if it is made of steel or aluminium.

A proposal to extend CBAM to more downstream goods is not adopted law, so it is not part of this list. Our article on the Parliament's position covers what that proposal says.

Direct emissions only, for some of the list

A second list, Annex II, names the goods "for which only direct emissions are to be taken into account" (Article 7(1)). It is not the same as Annex I: it includes iron and steel, aluminium, hydrogen and electricity entries, and no cement or fertiliser entries. For the goods on it, the electricity used to make them does not count towards their embedded emissions. Check your code there as well.

Try your code

Our CN lookup shows what the acts hold for a code you type. Which code your good falls under is a customs classification question about the good itself; the tool does not decide it, or whether it is covered, for you.