A price on steel and data: what’s next for the EU CBAM?
Joakim Granfors , secretary general of EFCEM, speaks with Lauren Hurrell about the opportunities for foodservice equipment manufacturers to strengthen competitiveness through lower emissions and greater supply-chain visibility as the EU CBAM regulation evolves
As Europe experiences a summer marked by recurring heatwaves and unusually high temperatures, attention is increasing on the greenhouse-gas emissions produced by fossil fuels and industrial processes. Industry, including steelmaking, has an important opportunity to contribute to emissions reductions under the European Green Deal, the EU's strategy to modernize its economy and achieve climate neutrality by 2050.
The Carbon Border Adjustment Mechanism was introduced to address carbon leakage: the risk that carbon-intensive production, and its associated emissions, shifts outside the EU as carbon costs increase.
CBAM is designed to support EU emissions cuts and help limit global emissions by reducing the risk that carbon-intensive production shifts outside the EU. It prices the embedded emissions of selected imports, including iron and steel, while a 50-tonne annual threshold exempts most smaller importers. Above that threshold, importers generally need to be authorized CBAM declarants and comply with the relevant declaration and certificate requirements. CBAM entered its definitive regime in January 2026, and the price of its certificates is linked to the EU ETS. Certificate sales begin on 1 February 2027 to cover the embedded emissions in 2026 imports.
The first annual CBAM declaration and certificate surrender deadline for 2026 imports is 30 September 2027, and this date will serve as the recurring annual deadline. The EU is considering extending CBAM to downstream steel- and aluminum-intensive products, with the proposal expected to be considered during the September plenary session. EFCEM is consulting its National Association Partners on the possible downstream extension. Members see both potential benefits for fair competition and practical concerns around data, costs and administration. EFCEM has not yet adopted a position and will consolidate members’ views before deciding its next steps.
“For EFCEM, CBAM is mainly a regulatory and competitiveness issue,” says Joakim Granfors, secretary general of EFCEM. “Most catering-equipment manufacturers will experience it through the market for stainless steel and components rather than through direct CBAM declarations.”
Understanding supply chains
These changes will impact EU importers, non-EU manufacturers, and downstream supply chains as pressure increases on customs classification, reliable emissions data, verification, and administration. CBAM will increasingly make traceability, customs classification and emissions information relevant subjects in supplier and manufacturer discussions.
“Most EFCEM members do not directly import stainless steel from outside the EU,” says Granfors. “They typically buy sheets, coils, fabricated parts or components from EU steel mills, service centers, distributors or EU-based importers. In those cases, the catering equipment manufacturer is not normally the CBAM declarant,” he adds.
“However, navigating CBAM will increasingly involve visibility of whether materials are EU-produced or imported, who the importer is, whether those materials fall within CBAM scope, and what origin and emissions data suppliers can provide,” adds Granfors.
Future implications
Today, CBAM applies to specific CN customs codes, the current list of which is set out in Annex I to the CBAM Regulation. For foodservice equipment manufacturing, this can include imported stainless-steel sheet, coils, bars, tubes, pipe fittings, fasteners and certain fabricated steel articles when they are declared under a CN code included in Annex I.
“In these cases, the legal CBAM obligation lies with the EU importer of record,” says Granfors. "Non-EU steel mills and suppliers exporting covered steel may need to provide emissions and production information; where actual emissions values are used, those values must be independently verified."
At present, finished commercial catering equipment is not generally included in the CBAM CN-code list.
“For EU catering-equipment manufacturers, CBAM can support fairer competition at material level, because EU steel mills already face ETS carbon costs,” says Granfors. "CBAM is intended to reduce the risk that imported covered steel which does not bear a comparable carbon cost gains a competitive advantage. For non-EU catering-equipment manufacturers, there is currently no CBAM certificate obligation on finished equipment exported to the EU when that equipment is classified outside the current CBAM list."
EFCEM aims to represent members' interests and ensure policymakers understand the sector's needs.
“The main risk is an unprepared supply chain – such as importers lacking authorisation, incomplete emissions data, or unclear customs classification,” says Granfors.
Opportunities in sight
Over the next year, financial compliance will be critical, with certified sales expected to begin on 1 February 2027 for emissions embedded in 2026 imports.
“The opportunity is greater transparency,” says Joakim. “Companies that understand the origin, classification and embedded emissions of their material inputs will be better prepared for the changing regulatory environment and able to engage more effectively with customers, suppliers and authorities.”
Scrap content is relevant, as European steelmaking benefits from mature recycling systems, though recycled content is not an automatic CBAM exemption. It will become increasingly useful for manufacturers to consider both recycled content and verified embedded emissions when discussing materials with suppliers.
The year ahead
Over the next year, regulatory readiness will be critical for direct EU importers of covered steel – ensuring authorized declarant status, correct customs codes, and reliable emissions information.
Non-EU steel mills exporting CBAM-covered products will increasingly need robust records, a clear grasp of the CBAM methodology, and early verification preparation.
“Verification is likely to be the most technically demanding part of CBAM,” says Granfors. "In simple terms, verification is an independent check that the emissions data linked to imported goods has been calculated correctly and is supported by reliable evidence. Verification is required when actual emissions data is used. It is much more than a supplier self-declaration: the verifier examines the production installation, fuel and electricity data, allocation of emissions to products and supporting records. The first verification generally involves a physical site visit."
Independent CBAM verifiers will be emissions auditors accredited by an EU or EEA national accreditation body. The first accredited CBAM verifiers are expected to be available from around September 2026.
The bottom line
In essence, CBAM does not currently impose a charge on imported finished catering equipment, but as the regulatory environment for steel and steel-containing supply chains shifts, the sector will benefit from staying informed and represented as the EU considers the next iterations of this regime.
“A practical starting point for EFCEM members is a structured dialogue with suppliers: clarifying the customs classification, the place of production, the emissions information available and, where relevant, whether that information can be independently verified,” says Granfors.