How to comply for this code
Reviewed by AutoCBAM team — last updated 2026-04-28.
Methodology guide -- CN 7210 (flat-rolled steel, coated)
CN 7210 covers galvanised, painted, tin-plated and aluminium-coated flat steel -- the workhorse of the appliance, automotive and construction supply chains. South Korea is the dominant exporter into the EU; China and Türkiye follow.
Step 1 -- subtract the coating mass before applying the emissions factor. A typical hot-dip galvanised coil has 100-275 g/m² zinc on each side -- about 1.5-3% of total mass on a 1mm-thick coil. The customs declaration includes coating weight; CBAM does not. Build a per-product coating-mass spreadsheet and apply it to every shipment.
Step 2 -- emissions are dominated by the upstream steel. Coating itself is a low-emission step (~0.05 t CO2/t). The dominant 1.9-2.4 t CO2/t direct emissions come from the upstream BF-BOF or EAF mill. If you import HDG from a non-integrated coater that takes its CRC from a third party, the coater's emissions are tiny -- but the CBAM declaration must capture the upstream emissions of the cold-rolled coil they bought.
Step 3 -- understand allocation for non-integrated coaters. Many suppliers (especially in Türkiye) buy CRC and coat locally. Reg. 2025/2621 Article 7 requires the importer to obtain a chained emissions report covering the full upstream value chain. A coater-only emissions report is invalid for CBAM.
Step 4 -- apply Article 9 deductions for K-ETS. Korean integrated coaters fall under K-ETS coverage. The K-ETS price (~KRW 8,000-12,000/t CO2 in 2026) deducts from your CBAM bill if documented properly.
Step 5 -- watch the year-end declaration deadline. All CBAM costs for calendar-year imports are settled by 31 May of the following year. Imports of CN 7210 in Q4 2026 must be reconciled by 31 May 2027.