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 2025/2621 Annex I (as replaced by IR 2026/1740) · 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.
Without a federal carbon price applicable to CBAM-covered goods, no Article 9 deduction is available for US exporters. State schemes do not meet Article 9 criteria. US exporters pay the full CBAM certificate cost on embedded emissions above the SEFA benchmark.
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 2025/2621 (EU 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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