How to comply for this code
Reviewed by AutoCBAM team — last updated 2026-04-28.
Methodology guide -- CN 7219 (stainless steel flat-rolled, ≥600mm wide)
Stainless flat is a high-value CBAM steel category dominated by China, Taiwan, South Korea and India. Per-tonne CBAM cost is higher than carbon steel due to the alloy content's embedded emissions.
Step 1 -- understand the production route. Stainless is EAF-dominated globally -- but the EAF here is a stainless-specific furnace fed with carbon steel + ferrochrome + ferronickel. Total direct emissions are 1.5-2.5 t CO2/t, slightly above the EU iron-steel default.
Step 2 -- watch for upstream alloy emissions. The chromium and nickel inputs carry embedded emissions of their own (ferrochrome ~3-4 t CO2/t Cr; ferronickel ~10-15 t CO2/t Ni). These are not separately declared under CBAM but are reflected in the supplier's scope 1 + 2 numbers when alloy production is on-site.
Step 3 -- request verified data; defaults under-state. The EU 1.88 t/t default is calibrated to carbon steel and is too low for stainless. Verified supplier data is more accurate -- and the verifier report should disclose the alloy mix and the upstream alloy emissions separately.
Step 4 -- handle Taiwan and South Korea favourably. Taiwanese stainless mills (Yieh United Steel, Walsin Lihwa) are EAF route; emissions sit at 1.5-1.8 t/t direct. Korean POSCO stainless is similar. Both jurisdictions have or are developing carbon pricing, opening Article 9 deductions over time.