CBAM for fastener and wire makers: what counts, and why your yield matters

Most fastener and wire plants make CBAM goods from steel they buy in: wire rod, bars or coil. The embedded emissions of what you ship are the emissions of your own processes plus the embedded emissions of that steel. For iron and steel goods only direct emissions count; electricity does not.

Which processes count

The EU calculation rules (Implementing Regulation (EU) 2025/2547, Annex I, point 3.16) count the fuel and process emissions of re-heating, re-melting, casting, hot and cold rolling, forging, annealing, coating, galvanizing, wire drawing and pickling. They leave out the emissions of plating, cutting, welding and finishing.

• Counted: furnaces for annealing and heat treatment, wire drawing, galvanizing and pickling lines.
• Not counted: the emissions of plating, cutting, welding and finishing steps.

The steel you buy is counted before cutting

The steel you use is counted by its mass as it enters your process, before any cutting. The Commission's own example: if 20% of the mass is cut away as scrap, 100 t of steel is needed for 80 t of product. All the embedded emissions of those 100 t go into the 80 t, so your figure per tonne rises even though cutting itself counts as zero. Ferrous scrap (CN 7204) is not a CBAM good, so the scrap you sell carries none of it away.

A worked example from the Commission

In the Commission's screws-and-nuts example, a plant buys 20,000 t of carbon steel with verified embedded emissions of 1.539 t CO2e a tonne and makes 17,000 t of screws and nuts. Its share of the natural gas burned is 3,337.95 t CO2.

• Steel: 20,000 × 1.539 = 30,780 t CO2e.
• Total: 3,337.95 + 30,780 = 34,117.95 t CO2e.
• Per tonne of screws and nuts: 34,117.95 ÷ 17,000 = 2.007 t CO2e.

The bought steel is 90% of the total. Because 15% of its mass did not end up in the product, it adds 1.81 t CO2e to each tonne shipped, 0.27 t more than its own figure of 1.539. Our emissions calculator reproduces this example exactly.

Why your yield is the lever

• Less scrap per tonne shipped means less steel per tonne, and a lower figure.
• The steel mill's verified figure matters most. Without it, the EU default value for that steel, with its mark-up, is used instead: see default values or actual emissions.
• Your furnaces and lines still count, so record fuel use per month from the start.

Work out your own figure with the emissions calculator, ask your mill for its data with the supplier letter, and keep the monthly records in the data workbook.

Sources: Commission Guidance Document 5D on iron and steel (14 August 2026), sections 2.2.3.8 and 4.3; Implementing Regulation (EU) 2025/2547, Annex I point 3.16 and Annex III point B. Not legal advice.