COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the Temporary Decarbonisation Fund
Date: 2026-03-16
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU environmental policy, EU industrial policy, aid to undertakings, fund (EU), goods, greenhouse gas, pollution control measures, production policy, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.3.2026  SWD(2026) 67 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the Temporary Decarbonisation Fund {COM(2025) 990 final/2}  
 
 
Contents 

1. 

2. 

Introduction: political and legal context .................................................................................... 2 

Problem definition ..................................................................................................................... 3 

3.  Determination of eligibility ........................................................................................................ 4 

3.1. 

Derivation of indicators to determine remaining carbon leakage risks ................................. 4 

3.1.1.  Background: Approach to determine the carbon leakage list in phase III and phase IV of 
the EU ETS ......................................................................................................................................... 4 

3.1.2. 

Indicators for remaining carbon leakage risks ....................................................................... 4 

3.2. 

3.3. 

3.4. 

Proposed approach to determine the remaining carbon leakage risk ..................................... 5 

Preferred option to determine eligibility of goods for the measure ....................................... 5 

Alternative option to determine eligibility of goods for the measure .................................... 6 

4.  A targeted approach for specific national circumstances ........................................................... 7 

5. 

6. 

Proposed conditionality design .................................................................................................. 8 

Engagement with stakeholders .................................................................................................. 9 

Annex 1: proposed list of eligible goods and respective TDFCL indicator ...................................... 11 

1 

 
 
 
 
 
 
1.  Introduction: political and legal context  

Regulation (EU) 2021/1119 of the European Parliament and of the Council (‘the European Climate 
Law’)1 sets a legally binding economy-wide target of net zero greenhouse gas emissions at the latest 
by  2050,  and  an  intermediate  target  of  reducing  net  greenhouse  gas  emissions  by  at  least  55%  by 
2030, compared to 1990 levels.2 

In  2025,  the  European  Commission  proposed  a  target  of  a  90%  reduction  in  net  greenhouse  gas 
(GHG)  emissions  by  2040,  compared  to  1990  levels.  This  proposed target  takes  full  account  of the 
current  economic,  security  and  geopolitical  landscape  in  alignment  with  the  EU  Competitiveness 
Compass3, and the Clean Industrial Deal4. It aims to provide the necessary predictability and stability 
for investments in the EU's clean energy transition and for driving industrial competitiveness.  

The  emissions  of  large  industrial  installations  are  regulated  by  the  EU  Emissions  Trading  System 
(ETS).  The  current  EU  ETS  legislation  sets  an  emission  reduction  target  of  62%  for  stationary 
installations, aviation and maritime (ETS1) by 2030 compared to 2005. In 2026, the Commission is 
planning to conduct a comprehensive review of the EU ETS, assessing how the EU ETS can best be 
adjusted  to  promote  cost-effective  emission  reductions  in  the  covered  sectors  in  line  with  climate 
neutrality in 2050 and the intermediate target for 2040. 

Over the coming decade, and to achieve climate neutrality by 2050, industry will have to go through a 
significant  transformation  to  decarbonise  and  switch  to  cleaner  and  more  energy  efficient 
technologies. This transformation requires stepping up investments, while remaining competitive and 
affordable.  The  deployment,  pace  and  scaling-up  of  existing  and  new  technologies  such  as 
electrification, carbon removals and carbon capture and utilisation will need both public and private 
support. 

In line with the overall reduction targets, and considering that free allocation dampens the price signal 
to  promote cost-effective emission  reductions,  the  current  EU  ETS1 framework has  built  in several 
mechanisms to reduce free allocation5 until 2030, including the update of benchmarks as well as the 
application  of  the  cross-sectoral  correction  factor.  For  a  limited  set  of  sectors  (i.e.  iron  &  steel, 
aluminium, cement, fertiliser, hydrogen), free allocation is additionally reduced by the CBAM factor6. 
Preliminary estimations suggest that a total of 15 million allowances less would be allocated free of 
charge7. Assuming a carbon price of EUR 95/tonne, this corresponds to an estimated EUR 1.4 billion. 
This  would  constitute  the  maximum  budget  needed  for  the  proposed  measure  (if  all  CBAM  goods 
were covered).  

1 Regulation (EU) 2021/1119. 
2 COM (2025)524. 
3 COM/2025/79 final. 
4 COM/2025/85. 
5 Auctioning is the default method for distributing emission allowances to installations and operators under the 
EU  ETS.  However,  in  certain  sectors,  the  transition  to  full  auctioning  is  taking  place  gradually.  As  the  EU 
continues  to  pursue  ambitious  emission  reductions  targets,  these  sectors  receive  some  allowances  for  free  to 
address the risk of carbon leakage. Free allocation under the EU ETS follows specific, harmonised rules. 
6  As  the  CBAM  is  progressively  phased  in  from  2026  onwards  for  goods  listed  in  Annex  I  of  the  CBAM 
Regulation  (Regulation  (EU)  2023/956),  the  ETS  Directive    provides  that  in  parallel,  free  allocation  for  the 
production of these goods by EU operators is reduced by the application of the CBAM factor. The CBAM factor 
is set at 97.5% in 2026,  and 95% in 2027. It further declines over subsequent years, until in 2034 no CBAM 
factor applies, meaning that free allocation for the production of CBAM goods is set at zero. 
7 Note that these figures are only indicative and likely to be underestimations. More precise estimations cannot 
be provided at this point, due to shortcomings in currently available ETS data. 

2 

 
 
 
For  these  sectors,  the  Carbon  Border  Adjustment  Mechanism  (CBAM)  is,  from  2026  onwards, 
gradually  phased in  as  a  complementary  form  of  protection  against  the  risk  of  carbon  leakage.  The 
CBAM addresses import-related carbon leakage risks for these sectors. The remaining risk of carbon 
leakage  is  not fully  prevented  by  Regulation  (EU)  2023/956  of the  European  Parliament  and  of the 
Council and should therefore be addressed through additional measures supporting the transition and 
promoting the decarbonisation of industrial sectors. Decarbonisation investments can help reduce the 
exposure of these operators to such carbon leakage risks in the mid- and long-term. The objective of 
the  present  proposal  is  thus  to  temporarily  support,  during  the  production  years  2026  and  2027, 
operators  producing  goods  associated  with  a  particularly  elevated  remaining  carbon  leakage  risk  to 
effectively invest in decarbonisation measures. A more permanent solution may be envisaged in the 
upcoming revision of the ETS Directive.  

Action at Union level is necessary to address the abovementioned risks in a consistent manner across 
Member States. Measures at national level could lead to uncoordinated support across the Union, thus 
leading to distortions in the internal market and weakening the overall effectiveness of the EU ETS. 

The measure to be proposed should be implemented quickly to provide legal certainty, and to avoid 
undue  administrative  burden.  The  proposed  temporary  decarbonisation  investment  support  should 
moreover be  precisely  targeted to production of goods with a heightened level of  remaining carbon 
leakage  risks,  in  order  to  be  proportionate  and  in  order  to  avoid  market  distortions.  The  present 
document  describes  how  these  needs  have  been  taken  into  account  in  the  design  of  the  proposed 
measure.  

2.  Problem definition 

The  decrease  in  emissions  under  the  EU  ETS  in  recent  years  was  largely  driven  by  the  electricity 
sector.  Emissions  in  the  energy  intensive  industries,  on  the  other  hand,  experienced  only  slight 
decreases, which were also partly explained by decreases in output. The availability and affordability 
of abatement options in these sectors is not yet at the level of the power sector. This points to a need 
for investment into decarbonisation measures in these sectors, because these investments are needed 
to achieve EU climate targets and reduce the risk of carbon leakage. 

Effective  carbon  costs  for  ETS  operators  are  expected  to  increase  as  free  allocation  is  reduced, 
notably for operators covered by the CBAM factor. This increased price signal for decarbonisation is 
expected  to  promote  cost-effective  GHG  emission  reductions.  However,  the  production  of  some 
goods might bear an increased risk of remaining carbon leakage which is not fully addressed by the 
CBAM.  

For the goods produced to be sold on the EU internal market, the risk of carbon leakage is addressed 
by  the  application  of  the  CBAM  which  will  ensure  that  products  produced  in  third  countries  and 
imported to the EU internal market will pay an equivalent carbon price to that payable if the goods 
were produced in the EU. It can be considered that this balances the impacts of the phase-out of free 
allocation.  However,  the  production  of  some  goods  can  still  be  considered  to  be  exposed  to  a 
remaining  carbon  leakage  risk  where  no  equivalent  carbon  pricing  is  in  place.  The  reduced  Union-
wide emissions cap, combined with the gradual phase-out of free allocation provided for in the ETS 
Directive,  requires  cost-intensive  and  rapid  adaptations  by  the  industries  covered  by  Directive 
2003/87/EC,  thereby  increasing  the  short-term  risk  of  carbon  leakage.  Operators  of  EU  ETS 
installations  producing  such  goods  are  expected  to  need  temporary  financial  support  to  accelerate 
investments into decarbonisation measures in order to ensure the effectiveness of the Union’s climate 
policy and in order to fully address this remaining risk of carbon leakage.  

3 

 
 
 
3.  Determination of eligibility 

3.1. 

Derivation of indicators to determine remaining carbon leakage risks 

3.1.1.  Background: Approach to determine the carbon leakage list in phase III 

and phase IV of the EU ETS 

In phase III of the EU ETS, a sector or sub-sector was considered to be at significant risk of carbon 
leakage if: 

•  direct  and  indirect  costs  induced  by  the  implementation  of  the  directive  would  increase 
production cost, calculated as a proportion of the gross value added, by at least 5%; and 
the sector's trade intensity with non-EU countries is above 10%. 

• 

A sector or sub-sector was also deemed to be exposed if: 

• 
• 

the sum of direct and indirect additional costs was at least 30%; or 
the non-EU trade intensity was above 30%. 

As a result, more than 250 sectors (at NACE 4 level), almost all industry sectors covered by the EU 
ETS, qualified for the carbon leakage list. 

In phase IV, the two separate indicators are replaced by a combined indicator. A sector or sub-sector 
is  deemed  to  be  at  risk  of  carbon  leakage  if  the  product  of  trade  intensity  and  emission  intensity 
exceeds 0.2: 

𝑡𝑟𝑎𝑑𝑒 𝑖𝑛𝑡𝑒𝑛𝑠𝑖𝑡𝑦  ∗ 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑖𝑛𝑡𝑒𝑛𝑠𝑖𝑡𝑦(

𝑘𝑔𝐶𝑂2
𝑔𝑟𝑜𝑠𝑠 𝑣𝑎𝑙𝑢𝑒 𝑎𝑑𝑑𝑒𝑑 (𝑖𝑛 €)

) > 0.2 

The carbon leakage list for phase IV is more focussed with a bit more than 50 sectors at NACE 4 level 
included in the list, while the list still covers all highly emission-intensive industry sectors. 

3.1.2.  Indicators for remaining carbon leakage risks 

To determine the remaining carbon leakage risk described above, the indicators used in phase III and 
phase IV of the EU ETS need to be adjusted. 

In phase III of the EU ETS, one of the two defining criteria was a carbon cost indicator while in phase 
IV it was an emission intensity indicator. Both approaches are capturing the same potential cause of 
carbon leakage. 

All CBAM goods are deemed to have a significantly high emission intensity. The CBAM Regulation8 
(recital 31) specifies that ‘[t]he goods, to which this Regulation should apply, should be selected after 
careful  analysis  of  their  relevance  in  terms  of  cumulated  greenhouse  gas  emissions  (...)’.  An 
additional analysis of the emission intensity would thus be redundant.  

The  trade  intensity  indicator  also  required  adjustments  to  focus  the  measure  on  the  remaining  risks 
after the application of the CBAM.  

8 Regulation (EU) 2023/956. 

4 

 
 
 
 
 
3.2. 

Proposed approach to determine the remaining carbon leakage risk 

The proposed decarbonisation fund will provide temporary financial support to operators of EU ETS 
installations  that  produce  goods  included  in  a  pre-defined  list  of  goods  considered  to  be  at  risk  of 
remaining  carbon  leakage.  In  order  to  define  this  list  of  goods  at  risk,  in  a  first  step,  the  scope  of 
potentially  eligible  goods  is  limited  to  goods  listed  in  Annex  I  of  the  Regulation  (EU)  2023/956 
(except electricity), since these are the goods for which free allocation is subject to the CBAM factor. 
As specified above, all listed CBAM goods have a significantly high emission intensity. To determine 
the goods which bear a high degree of risk of remaining carbon leakage, a meaningful and objective 
indicator,  called  the  “Temporary  Decarbonisation  Fund  Carbon  Leakage  (‘TDFCL’)  indicator”,  is 
applied. Considering the volatility of trade data, an average of the three most recent years (2022-2024) 
of PRODCOM data is used.  

Trade  intensity  data  with  Norway,  Iceland,  Liechtenstein  (as  part  of  the  EU  ETS)  and  Switzerland 
(existing linking with the EU ETS) are excluded from the calculation of the TDFCL indicator. Since 
goods produced in those jurisdictions are subject to an equivalent carbon price to that payable in the 
EU, and thus the production of goods traded with these countries does not give rise to a risk of carbon 
leakage.  Trade  intensity  data  with  the  UK  were  also  excluded  from  the  calculation  of  the  TDFCL 
indicator, since carbon prices in the UK ETS and EU ETS are comparable, and further converging in 
view of the political intention to link the EU ETS and the UK ETS (see figure 1). Consequently, the 
remaining carbon leakage risk on the UK market is expected to be very limited.  

Figure  1  comparsion  of  the  UK  ETS  and  EU  ETS  carbon  prices  (November  2024  -  December  2025).  Source:  International 
Cabon Action Partnership (ICAP) Allowance Price Explorer, accessed on 4 November 2025. 

3.3. 

Preferred option to determine eligibility of goods for the measure 

The  intention  of  the  proposed  temporary  decarbonisation  fund  is  to  provide  effective  investment 
support  for  decarbonisation  to  operators  producing  goods  for  which  the  remaining  carbon  leakage 

5 

 
 
 
 
 
risks  are  the  highest,  while  respecting  the  limited  budget  available  and  avoiding  the  creation  of 
potential market distortions.9 A meaningful eligibility threshold is needed to identify the goods which 
bear a high degree of risk of remaining carbon leakage. Operators of installations producing eligible 
goods may, conditional to meeting decarbonisation requirements, receive financial support based on 
the  amount  of free  allowances  phased  out  due  to the  application  of  the  CBAM  factor  as  defined  in 
Article 10a(1) 10. 

Assuming  that  the  equivalent  of  25%  of  the  CBAM  revenues  will  be  available,  we  estimate  the 
maximum  available  budget  to  be  around  EUR 632  million,  i.e.  EUR  308  million  corresponding  to 
25%  of  the  expected  revenues  generated  by  the  sale  of  CBAM  certificates  related  to  embedded 
emissions  declared  in  2026,  and  EUR  324  million  respectively  in  relation  to  embedded  emissions 
declared  in  202711.  However,  these  are  estimates  and  the  amount  available  for  compensation  will 
depend on the actual CBAM certificates prices and revenue in 2026 and 2027. 

The estimated costs for the Temporary Decarbonisation Fund are relatively small, due to the moderate 
free allocation reduction in 2026 and 2027 (2.5% and 5%). The estimated maximum budget needed if 
all  CBAM  goods  were  covered (EUR  1.4 billion)  exceeds the funds  available  which underlines  the 
need to target the measure by setting a threshold. 

The proposed threshold for support is the same as for the trade intensity threshold under Phase III of 
the  EU  ETS,  when  only  one  indicator  is  used  (30%).  This  provides  for  targeted  support.  Table  1 
provides an overview of the number of goods (CN codes) covered, as well as preliminary estimations 
of  the  phased-out  free  allowances  covered,  and  financial  support  provided  as  part  of  the  temporary 
measure. Overall, this threshold strikes the right balance between targeting the support to those goods 
most exposed to remaining carbon leakage and respecting the available budget.  

Table 1 overview of the number of goods (CN codes) covered, as well as preliminary estimations of the phased-out free 
allowances covered and financial support provided as part of the temporary measure for a threshold of > 30%. 

CN codes covered 

142 CN codes (of 570 analysed, 25%) 

Estimated phased-out 
FAs covered 

Estimated financial support 
(2026-2027) 

14% of phased-out free 
allowances covered 

EUR 190 million, i.e. 30% 
of assumed maximum 
available budget 

3.4. 

Alternative option to determine eligibility of goods for the measure 

An alternative option considered was to target the measure by setting the threshold higher (50%). This 
option  was  disregarded  since  only  a  very  small  share  of  CN  codes  and  phased-out  free  allowances 
would  be  covered,  risking  that  the  measure  falls  short  of  effectively  supporting  decarbonisation 
investments to a sufficient level and thus achieving the objective of preventing carbon leakage. 

9 The measure will be financed by Member States with an amount corresponding to up to 25% of the revenues 
generated by CBAM. 
10 Directive 2003/87/EC. 
11 Source: Commission estimations of CBAM revenues. 

6 

# CN codes% of CN codesIron & steel12727%Aluminium712%Cement00%Fertilisers830%Hydrogen00% 
 
  
 
 
 
Table 2  overview of the number of goods (CN codes) covered, as well as preliminary estimations of the phased-out free 
allowances covered and financial support provided as part of the temporary measure for a threshold of > 50%. 

CN codes covered 

Phased-out FAs covered  Estimated financial support 

63 CN codes (of 570 analysed, 11%) 

0.3% of phased-out free 
allowances covered 

(2026-2027) 

EUR 5 million, i.e. 1% of the 
MS share of assumed 
maximum available budget 

4.  A targeted approach for specific national circumstances 

While  the  production  of  certain  goods  does  not  have  high  levels  of  remaining carbon  leakage  risks 
when  assessed  at  an  EU-wide  level,  the  remaining  carbon  leakage  risks  might  nonetheless  be 
significantly  higher  when  assessed  at  Member  State  level  due  to  unique  national  circumstances.  In 
these  cases,  EU  ETS  operators  producing  the  affected  goods  might  also  be  in  need  of  temporary 
financial support to accelerate decarbonisation investments. 

Important factors for determining whether the production of goods is significantly more vulnerable at 
an individual  country level compared to the  EU-wide level are  geographic circumstances as well as 
the ratio between value and weight of goods. To account for the specific characteristics of goods with 
a  low  ratio  of  value  to  weight  with  regards  to  the  remaining  risk  of  carbon  leakage,  an  opt-in 
mechanism  should  be  established.  While  the  goods  set  out  in  the  Annex  demonstrate  a  particularly 
high Union-wide exposure, this opt-in mechanism should consider national circumstances, including 
transportation  costs.  The  production  of  low  value/weight  goods  in  specific  locations  might  have  a 
higher remaining carbon leakage risk. 

Data from Eurostat (production sold, both in value and quantity, 2022-2024) is used to determine the 
value/weight  ratio  per  CN  code.  A  preliminary  threshold  of  150  EUR/tonne  is  applied  to  identify 
goods  with  a  comparatively  low  value/weight  ratio.  These  goods  can  be  considered  to  have  a 
potentially significantly higher remaining carbon leakage risk when considered at national level. 

Table 3 goods considered to potentially have significantly higher remaining carbon leakage risks at national level, due to a 
comparatively low value/weight ratio 

It is proposed to address the associated risk through an opt-in mechanism, allowing Member States to 
apply for the inclusion of certain CN codes covered by CBAM with a low value/weight ratio in the 

7 

# CN codes% of CN codesIron & steel5812%Aluminium23%Cement00%Fertilisers311%Hydrogen00%CN codeDescription25070080Kaolinic clays (other than kaolin)25231000Cement clinkers25232100White portland cement, whether or not artificially coloured25232900Portland cement (excl. white, whether or not artificially coloured)25233000Aluminous cement25239000Cement, whether or not coloured (excl. portland cement and aluminous cement)26011200Agglomerated iron ores and concentrates (excl. roasted iron pyrites) 
 
  
  
 
 
 
 
   
proposed  measure  if  they  can  demonstrate  that  the  eligibility  criteria  foreseen  for  the  Annex  of  the 
Regulation  are  fulfilled  at  national  level.  This  allows  for  equal  treatment  between  producers  of  the 
same  goods within a Member State. It also represents a compromise compared to a more distortive 
and burdensome alternative of assessing leakage risk for individual installations.  

5.  Proposed conditionality design 

The  objective  of  the  proposed  Temporary  Decarbonisation  Fund  is  to  financially  support  effective 
decarbonisation  investments  by  EU  ETS  operators  producing  goods  which  bear  a  significant 
remaining  carbon  leakage  risk.  The  definition  of  ‘conditionality’  requirements  attached  to  the 
provision  of  financial  support  is  thus  a  central  element  of  the  proposed  fund.  Making  support 
conditional upon investment reflects a growing practice both in State aid guidelines12 and in the ETS 
Directive. 

To  limit  the  administrative  burden  of  the  new  measure,  and  to  capitalise  on  already  existing 
administrative ‘infrastructure’ and data reported for the purpose of free allocation under the EU ETS, 
various options that build on existing frameworks – from State aid and free allocation practice – were 
explored. Building on a combination of elements from those frameworks, a design making best use of 
already  reported  information  is  proposed  that  would  allow  companies  to  choose  between  the 
following: 

(EED)13:  The  demonstration  of 

(1)  For  operators  covered  by  the  obligation  to  conduct  an  energy  audit  under  the  Energy 
implementation  of  all 
Efficiency  Directive 
recommendations  under  Article 11  of  Directive  2023/1791/EC  or  alternatively  that  the  pay-
back time for the relevant investments exceeds five years or that the cost of those investments 
is  disproportionate.  In  the  latter  case,  the  operator  can  demonstrate  a  legal  commitment  for 
investments implementing other measures which lead to greenhouse gas emission reductions 
equivalent to those recommended by the audit report or by the certified energy management 
system for the installation concerned; or 

the 

(2)  For operators not covered by the obligation to conduct an energy audit under the EED:  The 
conditions above apply if they conduct an energy audit compliant with the minimum criteria 
set out in Annex VI of the EED; or 

(3)  For all operators: The demonstration of a legal commitment made for investments to achieve 
the  targets  and  milestones  referred  to  in  a  climate  neutrality  plan  compliant  with 
Implementing  Regulation  (EU)  2023/2441  and  which  is  at  least  equivalent  to  the  support 
amount applied for under this Regulation.  

The additional administrative burden of this proposed conditionality design is expected to be limited, 
while  at  the  same  time  compliance  with  the  proposed  framework  bear  meaningful  decarbonisation 
potential through targeted investments. More than five thousand EU ETS installations are estimated to 
already  be  covered  by  the  EED  energy  audit  requirements,  and  over  three  hundred  EU  ETS 
installations are estimated to be affected by the CNP conditionality. Around 96% of those installations 
whose greenhouse gas emission levels are higher than the 80th percentile of emission levels for the 
relevant  product  benchmarks  relating  to  the  implementation  of  the  fifth  subparagraph  of  Article 
10a(1)  of  Directive  2003/87/EC,  submitted  their  climate-neutrality  plan  to  the  competent  authority. 
Around  4%  of  all  installations  applying  for  free  allocations  applied  the  20%  reduction  due  to  non-
compliance with the energy efficiency conditionality requirements. 

12 See e.g. the ETS State aid Guidelines post-2021, the Guidelines on State aid for Climate, Environmental 
protection and Energy (CEEAG) and the Clean Industrial Deal State Aid Framework (CISAF). 
13 Cf.Directive 2012/27/EU and Directive 2023/1791/EC. 

8 

 
 
 
 
On average, 52% of all installations with energy efficiency improvements under Article 8 of the EED 
indicated that they implemented all measures. This indicates that while operators have already taken 
significant  steps,  aimed  at  improving  energy  efficiency,  there  is  still  room  for  additional  efforts  in 
strengthening energy efficiency measures. 

The  additional  administrative  steps  that  need  to  be  carried  out  by  installations  that  want  to  receive 
support  from  the  TDF  include  an  application  to  the  fund,  a  proof  of  meeting  the  conditionality 
requirements.  In  addition,  an  activity  level  report  already  required  under  the  EU  ETS  needs  to  be 
provided at a slightly more granular level to differentiate between production volumes of eligible and 
non-eligible CBAM goods. The additional administrative burden is, hence, minimal in comparison to 
the support received and the positive environmental impact of the fund. 

6.  Engagement with stakeholders 

The Commission is committed to being open and transparent throughout the policy cycle, including in 
the  consultation  of  stakeholders.  The  Commission  has  organised  a  targeted  consultation  activity, 
seeking  the  specific  views  of  well  defined  stakeholders.  The  Commission  consulted  industry 
representatives  on  the  plan  for  a  support  measure  in  advance  of  the  proposal,  including  through  a 
high-level dialogue organised on 28 October.  

Overview: consultation activities  

Date 

Consultation activity 

Participants 

08 August 2024 

Stakeholder Engagement Questionnaire 

Industry representatives14 

19 September 2025 

CBAM industry breakfast 

22 October 2025 

Stakeholder workshop on carbon leakage 
risks and eligibility for a support measure 

Industry representatives15 

Industry representatives16 

28 October 2025 

High-Level Dialogue 

Industry representatives17 

During these consultation activities, the Commission informed stakeholders about the planned support 
measure, including plans for its overall design and reflections about the eligibility for support and the 
conditions that would need to be fulfilled to receive it. 

14 Cembureau, Eurofer, CAEF, European Aluminium, Fertilisers Europe, Hydrogen Europe, Renewable 
Hydrogen Alliance, European Industrial Gases Association. 
15 Cembureau, Cefic, Euroalliages, European Aluminium, Eurofer, Eurometaux, Fertilizers Europe, Hydrogen 
Europe, European Steel Processors Association. 
16  Hydrogen  Europe,  Cement  Europe,  Eurofer,  Cefic,  Renewable  Hydrogen  Coalition,  Fertilizers  Europe, 
Euroalliages, FuelsEurope, BusinessEurope, Eurometaux, Business for CBAM Coalition, Renewable Hydrogen 
Alliance. 
17 Acea, Alro, Applia, ArcelorMittal, Arvedi Group, Bellona, Business Europe, Business for CBAM Coalition, 
Celsa  Group,  Cement  Europe,  EFDA  (European  Fastener  Distributor  Association),  Energy  Traders  Europe, 
Entso-E,  Eurelectric,  Euroalliages,  Eurochambres,  Eurofer,  Eurometaux,  EuropaCable,  European  Aluminium, 
European  Tool  Association,  Fertilizers  Europe,  FIM  (Fédération  des  Industries  Mécaniques),  Groupe  SEB, 
Grupa Azoty, Heidelberg Materials, Holcim, Hüttenwerke Krupp Mannesmann, Marcegaglia, Metal Packaging 
Europe,  NKT,  Norsk  Hydro,  Orgalim,  Outokumpu,  Riva  Group,  Stahlwille  Holding,  Thyssenkrupp,  Timet 
Aluminium SE, Titan Group, UNIFE, VDMA , Voestalpine Group, Yara International. 

9 

 
 
 
 
 
Stakeholders provided their feedback notably on the following points: 

•  need for a support measure 

o  Some  stakeholders  pointed  out  that  there  is  an  urgent  need  for  a  measure  tackling  the 

remaining carbon leakage risk, notably in light of the phase-out of free allocation. 

• 

form of support 

o  Many stakeholders asked for a delay of the phase-out of free allocation. 
o  Many  stakeholders  asked  not  to  use  State  Aid  as  support  mechanism  to  avoid  unequal 
treatment  between  operators  located  in  different  Member  States.  Several  stakeholders 
pointed out the importance of ensuring WTO compatibility. 

• 

eligibility for support 

o  Some stakeholders mentioned the need to also consider downstream products. 
o  Some stakeholders pointed out that it is important to also consider national differences. 
o  Some  stakeholders  argued  that  they  would  prefer  support  for  producers  depending  on 

their trade intensity. 

o  Some stakeholders expressed scepticism about the level of disaggregation of the analysis 

(at 8-digit CN code level). 

o  Some stakeholders remarked that trade patterns are volatile and that the  trade data  used 

from 2022 until 2024 would be marked by post-Covid and the energy crisis. 

• 

conditions for receiving support  

o  Some stakeholders asked for the conditionality to be simple and not too bureaucratic. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 1: proposed list of eligible goods and respective TDFCL indicator 

Aluminium 

CN code 

Description 

76069100 

Plates, sheets and strip, of non-alloy aluminium, of a thickness of > 0,2 mm (other than 
square or rectangular) 

76072010 

Aluminium foil, backed, of a thickness (excl. any backing) of < 0,021 mm (excl. stamping 
foils of heading 3212, and foil made up as christmas tree decorating material) 

76051900 

Wire of non-alloy aluminium, with a maximum cross-sectional dimension of <= 7 mm 
(other than stranded wires, cables, ropes and other articles of heading 7614, electrically 
insulated wires, strings for musical instruments) 

 TDFCL 
Indicator 
0.60 

0.38 

1.34 

Aluminium foil, not backed, rolled and further worked, of a thickness of < 0,021 mm (excl. 
stamping foils of heading 3212, and foil made up as christmas tree decorating material) 

0.41 

76071910 

76032000 

Powders of aluminium, of lamellar structure, and flakes of aluminium (excl. pellets of 
aluminium, and spangles) 

76161000 

Nails, tacks, staples, screws, bolts, nuts, screw hooks, rivets, cotters, cotter pins, washers 
and similar articles, of aluminium (excl. staples in strips, plugs, bungs and the like, 
threaded) 

0.46 

0.45 

76061130  Aluminium Composite Panel, of non-alloy aluminium, of a thickness of > 0,2 mm 

0.34 

Fertilisers 

CN code 

Description 

28342100  Nitrate of potassium 

31026000 

Double salts and mixtures of calcium nitrate and ammonium nitrate (excl. those in tablets 
or similar forms, or in packages with a gross weight of <= 10 kg) 

31051000 

Mineral or chemical fertilisers of animal or vegetable origin, in tablets or similar forms, or 
in packages with a gross weight of <= 10 kg 

31052010 

Mineral or chemical fertilisers containing phosphorus and potassium, with a nitrogen 
content > 10 % by weight on the dry anhydrous product (excl. those in tablets or similar 
forms, or in packages with a gross weight of <= 10 kg) 

31054000 

Ammonium dihydrogenorthophosphate "monoammonium phosphate", whether or not 
mixed with diammonium hydrogenorthophosphate "diammonium phosphate" (excl. that in 
tablets or similar forms, or in packages with a gross weight of <= 10 kg) 

31055100 

Mineral or chemical fertilisers containing nitrates and phosphates (excl. ammonium 
dihydrogenorthophosphate "Monoammonium phosphate", diammonium 
hydrogenorthophosphate "Diammonium phosphate", and those in tablets or similar forms, 
or in packages with a gross weight of <= 10 kg) 

 TDFCL 
Indicator 
1.16 
0.75 

0.35 

0.32 

1.10 

0.42 

11 

 
 
 
 
31055900 

Mineral or chemical fertilisers containing the two fertilising elements nitrogen (excl. 
nitrate) and phosphorus but not nitrates (excl. ammonium dihydrogenorthophosphate 
"monoammonium phosphate", diammonium hydrogenorthophosphate "diammonium 
phosphate" in tablets or similar forms, or in packages with a gross weight of <= 10 kg) 

31059080 

Mineral or chemical fertilisers containing the two fertilising elements nitrogen and 
potassium, or one main fertilising element, incl. mixtures of animal or vegetable fertilisers 
with chemical or mineral fertilisers, not containing nitrogen or with a nitrogen content, by 
weight, of <= 10% (excl. in tablets or similar forms or in packages of a gross weight of <= 
10 kg) 

0.43 

0.44 

Iron and steel 

CN code 

Description 

26011200  Agglomerated iron ores and concentrates (excl. roasted iron pyrites) 

72011019 

Non-alloy pig iron in pigs, blocks or other primary forms, containing by weight <= 0,5% 
phosphorus, >= 0,4% manganese and > 1% silicon 

72012000 

Non-alloy pig iron in pigs, blocks or other primary forms, containing by weight >= 0,5% 
phosphorus 

72015010 

Alloy pig iron in pigs, blocks or other primary forms, containing by weight >= 0,3% but 
<= 1% titanium and >= 0,5% but <= 1% vanadium 

72015090 

Alloy pig iron and spiegeleisen, in pigs, blocks or other primary forms (excl. alloy iron 
containing, by weight, >= 0,3% but <= 1% titanium and >= 0,5% but <= 1% vanadium) 

72021180 

Ferro-manganese, containing by weight > 2% carbon (excl. ferro-manganese with a 
granulometry of <= 5 mm and containing by weight > 65% manganese) 

72021900  Ferro-manganese, containing by weight <= 2% carbon 
72024190  Ferro-chromium, containing by weight > 6% carbon 
72024910  Ferro-chromium, containing by weight <= 0,05% carbon 
72026000  Ferro-nickel 

72039000 

Spongy ferrous products, obtained from molten pig iron by atomisation, iron of a purity of 
>= 99,94%, in lumps, pellets or similar forms 

72052100 

Powders, of alloy steel (excl. powders of ferro-alloys and radioactive iron powders 
"isotopes") 

72052900 

Powders, of pig iron, spiegeleisen, iron or non-alloy steel (excl. powders of ferro-alloys 
and radioactive iron powders "isotopes") 

72072039 

Semi-finished products of iron or non-alloy steel, containing by weight >= 0,25% carbon, 
of rectangular "other than square" cross-section and the width >= twice the thickness, 
forged 

72081000 

Flat-rolled products of iron or non-alloy steel, of a width of >= 600 mm, in coils, simply 
hot-rolled, not clad, plated or coated, with patterns in relief directly due to the rolling 
process 

72099020 

Flat-rolled products of iron or steel, of a width of >= 600 mm, cold-rolled "cold-reduced" 
and further worked, but not clad, plated or coated, perforated 

72101100 

Flat-rolled products of iron or non-alloy steel, of a width of >= 600 mm, hot-rolled or 
cold-rolled "cold-reduced", tinned, of a thickness of >= 0,5 mm 

12 

 TDFCL 
Indicator 

0.38 
0.33 

1.78 

1.38 

0.49 

0.36 

0.38 
0.32 
0.88 
0.41 
0.58 

0.32 

0.48 

1.15 

0.33 

0.32 

0.34 

 
 
 
72101220 

Tinplate of iron or non-alloy steel, of a width of >= 600 mm and of a thickness of < 0,5 
mm, tinned [coated with a layer of metal containing, by weight,  >= 97% of tin], not 
further worked than surface-treated 

72107010 

Tinplate of a width of >= 600 mm and of a thickness of < 0,5 mm, tinned [coated with a 
layer of metal containing, by weight,  >= 97% of tin], not further worked than varnished, 
and flat products plated or coated with chromium oxides or with chromium and chromium 
oxides, of iron or non-alloy steel, of a width of >= 600 mm, hot-rolled or cold-rolled 
"cold-reduced", varnished 

72109040 

Flat-rolled products of iron or non-alloy steel, tinned and printed, of a width of >= 600 
mm, hot-rolled or cold-rolled "cold-reduced" 

72124020 

Tinplate of a width of < 600 mm and of a thickness of < 0,5 mm, tinned [coated with a 
layer of metal containing, by weight,  >= 97% of tin], not further worked than varnished, 
and flat products plated or coated with chromium oxides or with chromium and chromium 
oxides, of iron or non-alloy steel, of a width of < 600 mm, hot-rolled or cold-rolled "cold-
reduced", varnished 

72124080 

Flat-rolled products of iron or non-alloy steel, of a width of < 600 mm, hot-rolled or cold-
rolled "cold-reduced", painted, varnished or plastic coated (excl. tinplate, not further 
worked than varnished, and products plated or coated with chromium oxides or with 
chromium and chromium oxides, varnished) 

72139120 

Bars and rods, hot-rolled, of the type used for tyre cord, smooth, of iron or non-alloy steel, 
in irregularly wound coils 

72189920 

Semi-finished products of stainless steel, of circular cross-section or of cross-section other 
than square or rectangular, rolled or obtained by continuous casting 

72202089 

Flat-rolled products of stainless steel, of a width of < 600 mm, not further worked than 
cold-rolled "cold-reduced", of a thickness of <= 0,35 mm and containing by weight < 
2,5% nickel 

72209020 

Flat-rolled products of stainless steel, of a width of < 600 mm, hot-rolled or cold-rolled 
"cold-reduced" and further worked, perforated 

Bars and rods of stainless steel, not further worked than hot-rolled, hot-drawn or extruded, 
of circular cross-section measuring < 80 mm and containing by weight < 2,5% nickel 

0.42 

0.43 

0.39 

0.43 

0.40 

0.30 

0.38 

0.36 

0.32 

0.31 

Bars and rods of stainless steel, not further worked than hot-rolled, hot-drawn or extruded, 
containing by weight < 2,5% nickel (excl. such products of circular cross-section) 

0.35 

72222011 

Bars and rods of stainless steel, of circular cross-section of a diameter >= 80 mm, simply 
cold-formed or cold-finished, containing by weight >= 2,5% nickel 

72222019 

Bars and rods of stainless steel, of circular cross-section of a diameter >= 80 mm, simply 
cold-formed or cold-finished, containing by weight < 2,5% nickel 

72222021 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, of 
circular cross-section measuring >= 25 mm but < 80 mm and containing by weight >= 
2,5% nickel 

72222029 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, of 
circular cross-section measuring >= 25 mm but < 80 mm and containing by weight < 
2,5% nickel 

0.43 

0.53 

0.30 

0.55 

13 

72221189 

72221990 

 
 
72222031 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, of 
circular cross-section measuring < 25 mm and containing by weight >= 2,5% nickel 

72222039 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, of 
circular cross-section measuring < 25 mm and containing by weight < 2,5% nickel 

72222081 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, 
containing by weight >= 2,5% nickel (excl. such products of circular cross-section) 

72222089 

Bars and rods of stainless steel, not further worked than cold-formed or cold-finished, 
containing by weight < 2,5% nickel (excl. such products of circular cross-section) 

72224010 

Angles, shapes and sections of stainless steel, only hot-rolled, only hot-drawn or only 
extruded 

72224090 

Angles, shapes and sections of stainless steel, cold-formed or cold-finished and further 
worked, or not further worked than forged, or forged, or hot-formed by other means and 
further worked, n.e.s. 

72230091 

Wire of stainless steel, in coils, containing by weight < 2,5% nickel, 13% to 25% 
chromium and 3,5% to 6% aluminium (excl. bars and rods) 

72251100  Flat-rolled products of silicon-electrical steel, of a width of >= 600 mm, grain-oriented 

72254040 

Flat-rolled products of alloy steel other than stainless, of a width of >= 600 mm, not 
further worked than hot-rolled, not in coils, of a thickness of > 10 mm (excl. products of 
tool steel, high-speed steel or silicon-electrical steel) 

72254060 

Flat-rolled products of alloy steel other than stainless, of a width of >= 600 mm, not 
further worked than hot-rolled, not in coils, of a thickness of >= 4,75 mm but <= 10 mm 
(excl. products of tool steel, high-speed steel or silicon-electrical steel) 

72254090 

Flat-rolled products of alloy steel other than stainless, of a width of >= 600 mm, not 
further worked than hot-rolled, not in coils, of a thickness of < 4,75 mm (excl. products of 
tool steel, high-speed steel or silicon-electrical steel) 

72255020 

Flat-rolled products of high-speed steel, of a width of >= 600 mm, not further worked 
than cold-rolled "cold-reduced" 

72255080 

Flat-rolled products of alloy steel other than stainless, of a width of >= 600 mm, not 
further worked than cold-rolled "cold-reduced" (excl. products of high-speed steel or 
silicon-electrical steel) 

72259900 

Flat-rolled products of alloy steel other than stainless, of a width of >= 600 mm, hot-
rolled or cold-rolled "cold-reduced" and further worked (excl. plated or coated with zinc 
and products of silicon-electrical steel) 

72261100 

Flat-rolled products of silicon-electrical steel, of a width of < 600 mm, hot-rolled or cold-
rolled "cold-reduced", grain-oriented 

72262000 

Flat-rolled products of high-speed steel, of a width of <= 600 mm, hot-rolled or cold-
rolled "cold-reduced" 

72281090 

Bars and rods of high-speed steel, not further worked than cold-formed or cold-finished, 
whether or not further worked, or hot-formed and further worked (excl. forged products, 
semi-finished products, flat-rolled products and hot-rolled bars and rods in irregularly 
wound coils) 

0.34 

0.62 

0.49 

0.45 

1.47 

4.01 

0.53 

0.33 
0.52 

0.55 

0.34 

1.07 

0.32 

0.81 

0.54 

0.34 

0.39 

14 

 
 
Bars and rods of silico-manganese stee, of square or other than rectangular cross-section, 
only cold-formed or cold-finished, incl. further worked, or hot-rolled and further worked 
(excl. hot-rolled, hot drawn or extruded, not further worked than clad, semi-finished 
products, flat-rolled products and hot-rolled bars and rods in irregularly wound coils) 

72282099 

72283020 

Bars and rods of tool steel, only hot-rolled, only hot-drawn or only extruded (excl. semi-
finished products, flat-rolled products and hot-rolled bars and rods in irregularly wound 
coils) 

72284010 

Bars and rods of tool steel, only forged (excl. semi-finished products, flat-rolled products 
and hot-rolled bars and rods in irregularly wound coils) 

72285020 

Bars and rods of tool steel, only cold-formed or cold-finished (excl. semi-finished 
products, flat-rolled products and hot-rolled bars and rods in irregularly wound coils) 

72285069 

Bars and rods of alloy steel, other than stainless steel, not further worked than cold-
formed or cold-finished, of circular cross-section, of a diameter of < 80 mm (excl. of 
high-speed steel, silico-manganese steel, tool steel, articles of subheading 7228.50.40, 
semi-finished products, flat-rolled products and hot-rolled bars and rods in irregularly 
wound coils) 

72285080 

Bars and rods of alloy steel, other than stainless steel, not further worked than cold-
formed or cold-finished (excl. of circular cross-section and products of high-speed steel, 
silico-manganese steel, tool steel, articles of subheading 7228.50.40, semi-finished 
products, flat-rolled products and hot-rolled bars and rods in irregularly wound coils) 

72299050 

Wire of steel containing by weight 0,9% to 1,1% of carbon, 0,5% to 2% of chromium and, 
if present, <= 0,5% of molybdenum, in coils (excl. rolled bars and rods) 

73011000 

Sheet piling of iron or steel, whether or not drilled, punched or made from assembled 
elements 

73041910 

Line pipe of a kind used for oil or gas pipelines, seamless, of iron or steel, of an external 
diameter of <= 168,3 mm (excl. products of stainless steel or of cast iron) 

Line pipe of a kind used for oil or gas pipelines, seamless, of iron or steel, of an external 
diameter of > 168,3 mm but <= 406,4 mm (excl. products of stainless steel or of cast iron) 

73041930 

73041990 

Line pipe of a kind used for oil or gas pipelines, seamless, of iron or steel, of an external 
diameter of > 406,4 mm (excl. products of stainless steel or of cast iron) 

73042200  Drill pipe, seamless, of stainless steel, of a kind used in drilling for oil or gas 
73042400  Casing and tubing, seamless, of a kind used for drilling for oil or gas, of stainless steel 

73042910 

Casing and tubing of a kind used for drilling for oil or gas, seamless, of iron or steel, of an 
external diameter <= 168,3 mm (excl. products of cast iron) 

73042930 

Casing and tubing of a kind used for drilling for oil or gas, seamless, of iron or steel, of an 
external diameter > 168,3 mm, but <= 406,4 mm (excl. products of cast iron) 

73042990 

Casing and tubing of a kind used for drilling for oil or gas, seamless, of iron or steel, of an 
external diameter > 406,4 mm (excl. products of cast iron) 

73043180 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of iron or non-alloy 
steel, cold-drawn or cold-rolled "cold-reduced" (excl. cast iron products, line pipe of a 
kind used for oil or gas pipelines, casing and tubing of a kind used for drilling for oil or 
gas and precision tubes) 

0.35 

0.52 

0.67 

1.19 

0.36 

0.31 

0.34 

1.05 

0.81 

0.91 

0.68 

0.52 
1.14 
0.99 

0.70 

0.96 

0.39 

15 

 
 
73044100 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of stainless steel, 
cold-drawn or cold-rolled "cold-reduced" (excl. line pipe of a kind used for oil or gas 
pipelines, casing and tubing of a kind used for drilling for oil or gas) 

73044983 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of stainless steel, of 
an external diameter of <= 168,3 mm (excl. cold-drawn or cold-rolled, line pipe of a kind 
used for oil or gas pipelines, and casing and tubing of a kind used for drilling for oil or gas 
and tubes) 

73044985 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of stainless steel, of 
an external diameter of > 168,3 mm but <= 406,4 mm (excl. cold-drawn or cold-rolled, 
line pipe of a kind used for oil or gas pipelines, and casing and tubing of a kind used for 
drilling for oil or gas and tubes) 

73044989 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of stainless steel, of 
an external diameter of > 406,4 mm (excl. cold-drawn or cold-rolled, line pipe of a kind 
used for oil or gas pipelines, and casing and tubing of a kind used for drilling for oil or gas 
and tubes) 

73045181 

Precision tubes, seamless, of circular cross-section, of alloy steel other than stainless, 
cold-drawn or cold-rolled "cold-reduced" (excl. line pipe of a kind used for oil or gas 
pipelines, casing and tubing of a kind used for drilling for oil and tubes, and pipes and 
hollow profiles, straight and of uniform wall-thickness, containing by weight >= 0,9% but 
<= 1,15% carbon and >= 0,5% but <= 2% chrome, whether or not containing by weight 
<= 0,5% molybdenum) 

73045189 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of alloy steel other 
than stainless, not cold-drawn or cold-rolled "cold-reduced" (excl. line pipe of a kind used 
for oil or gas pipelines, casing and tubing of a kind used for drilling for oil, precision 
tubes, and , pipes and hollow profiles, straight and of uniform wall-thickness, containing 
by weight >= 0,9% but <= 1,15% carbon and >= 0,5% but <= 2% chrome, whether or not 
containing by weight <= 0,5% molybdenum) 

73045930 

Tubes, pipes and hollow profiles of alloy steel (excl. stainless), seamless, of circular 
cross-section (not cold-drawn or cold-rolled), straight and of uniform wall-thickness, 
containing by weight >= 0,9% but <= 1,15% carbon and >= 0,5% but <= 2% chromium, 
whether or not containing by weight <= 0,5% molybdenum (excl. tubes, pipes and hollow 
profiles of subheadings 7304 19 to 7304 29) 

73045982 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of alloy steel other 
than stainless, of an external diameter of <= 168,3 mm (excl. cold-drawn or cold-rolled, 
line pipe of a kind used for oil or gas pipelines, casing and tubing of a kind used for 
drilling for oil or gas, and products of subheading 7304 59 30) 

73045983 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of alloy steel other 
than stainless, of an external diameter of > 168,3 mm but <= 406,4 mm (excl. cold-drawn 
or cold-rolled, line pipe of a kind used for oil or gas pipelines, casing and tubing of a kind 
used for drilling for oil or gas, and products of subheading 7304 59 30) 

73045989 

Tubes, pipes and hollow profiles, seamless, of circular cross-section, of alloy steel other 
than stainless, of an external diameter of > 406,4 mm (excl. cold-drawn or cold-rolled, 
line pipe of a kind used for oil or gas pipelines, casing and tubing of a kind used for 
drilling for oil or gas, and products of subheading 7304 59 30) 

0.38 

0.45 

0.75 

0.70 

0.31 

0.37 

0.30 

0.39 

0.32 

0.35 

73049000 

Tubes, pipes and hollow profiles, seamless, of non-circular cross-section, of iron or steel 
(excl. products of cast iron) 

2.10 

16 

 
 
73051100 

Line pipe of a kind used for oil or gas pipelines, having circular cross-sections and an 
external diameter of > 406,4 mm, of iron or steel, longitudinally submerged arc welded 

73051200 

Line pipe of a kind used for oil or gas pipelines, having circular cross-sections and an 
external diameter of > 406,4 mm, of iron or steel, longitudinally arc welded (excl. 
products longitudinally submerged arc welded) 

73052000 

Casing of a kind used in drilling for oil or gas, having circular cross-sections and an 
external diameter of > 406,4 mm, of flat-rolled products of iron or steel 

73061900 

Line pipe of a kind used for oil or gas pipelines, welded, of flat-rolled products of iron or 
steel, of an external diameter of <= 406,4 mm (excl. products of stainless steel or of cast 
iron) 

73062100 

Casing and tubing of a kind used in drilling for oil or gas, welded, of flat-rolled products 
of stainless steel, of an external diameter of <= 406,4 mm 

73062900 

Casing and tubing of a kind used in drilling for oil or gas, welded, of flat-rolled products 
of iron or steel, of an external diameter of <= 406,4 mm (excl. products of stainless steel 
or of cast iron) 

73069000 

Tubes, pipes and hollow profiles "e.g., open seam, riveted or similarly closed", of iron or 
steel (excl. of cast iron, seamless or welded tubes and pipes and tubes and pipes having 
internal and external circular cross-sections and an external diameter of > 406,4 mm) 

73071910  Tube or pipe fittings of cast iron (excl. of non-malleable) 
73071990  Cast tube or pipe fittings of steel 
73072100  Flanges of stainless steel (excl. cast products) 
73072210  Sleeves, of stainless steel, threaded (excl. cast products) 
73072290  Elbows and bends, of stainless steel, threaded (excl. cast products) 
73072310  Butt welding elbows and bends of stainless steel (excl. cast products) 

73072910 

Threaded tube or pipe fittings of stainless steel (excl. cast products, flanges, elbows, bends 
and sleeves) 

73072980 

Tube or pipe fittings of stainless steel (excl. cast, threaded, butt welding fittings and 
flanges) 

73079100  Flanges of iron or steel (excl. cast or stainless products) 
73079210  Sleeves of iron or steel, threaded (excl. cast or of stainless steel) 
73079290  Elbows and bends, of iron or steel, threaded (excl. cast or of stainless steel) 

73079311 

Butt welding elbows and bends, of iron or steel, with greatest external diameter <= 609,6 
mm (excl. cast iron or stainless steel products) 

73079319 

Butt welding fittings of iron or steel, with greatest external diameter <= 609,6 mm (excl. 
cast iron or stainless steel products, elbows, bends and flanges) 

73079391 

Butt welding elbows and bends, of iron or steel, with greatest external diameter > 609,6 
mm (excl. cast iron or stainless steel products) 

73079399 

Butt welding fittings of iron or steel, with greatest external diameter > 609,6 mm (excl. 
cast iron or stainless steel products, elbows, bends and flanges) 

73079910 

Threaded tube or pipe fittings, of iron or steel (excl. cast iron or stainless steel products, 
flanges, elbows, bends and sleeves) 

73079980 

Tube or pipe fittings, of iron or steel (excl. of cast iron or stainless steel, threaded, butt 
welding fittings, and flanges) 

0.51 

0.43 

0.59 

0.37 

0.51 

6.34 

0.37 

0.30 
0.48 
0.48 
0.72 
0.36 
0.34 
0.44 

0.41 

0.87 
0.92 
0.63 
0.54 

0.38 

0.73 

0.49 

0.70 

0.61 

17 

 
 
73110013 

Containers of iron or steel, seamless, for compressed or liquefied gas, for a pressure >= 
165 bar, of a capacity >= 20 l to <= 50 l (excl. containers specifically constructed or 
equipped for one or more types of transport) 

73181100  Coach screws of iron or steel 
73181300  Screw hooks and screw rings, of iron or steel 
73181410  Self-tapping screws, of stainless steel (excl. wood screws) 

73181535 

Screws and bolts, of stainless steel "whether or not with their nuts and washers", without 
heads (excl. screws and bolts for fixing railway track construction material) 

73181548 

Screws and bolts, of iron or steel other than stainless "whether or not with their nuts and 
washers", without heads, with a tensile strength of >= 800 MPa (excl. screws and bolts for 
fixing railway track construction material) 

73181568 

Hexagonal-socket head screws and bolts, of iron or steel other than stainless "whether or 
not with their nuts and washers" (excl. wood screws, self-tapping screws and screws and 
bolts for fixing railway track construction material) 

73181575 

Hexagon screws and bolts, of stainless steel "whether or not with their nuts and washers" 
(excl. with socket head, wood screws, self-tapping screws and screws and bolts for fixing 
railway track construction material) 

73181588 

Hexagon screws and bolts, of iron or steel other than stainless "whether or not with their 
nuts and washers", with a tensile strength of => 800 MPa (excl. with socket head, wood 
screws, self-tapping screws and screws and bolts for fixing railway track construction 
material) 

73181595 

Screws and bolts, of iron or steel "whether or not with their nuts and washers", with heads 
(excl. with slotted, cross-recessed or hexagonal head; wood screws, self-tapping screws 
and screws and bolts for fixing railway track construction material, screw hooks and 
screw rings) 

73181631  Blind rivet nuts of stainless steel 
73181639  Nuts of stainless steel (excl. blind rivet nuts) 
73181640  Blind rivet nuts of iron or steel other than stainless 
73181660  Self-locking nuts of iron or steel other than stainless 

73181692 

Nuts of iron or steel other than stainless, with an inside diameter <= 12 mm (excl. blind 
rivet nuts and self-locking nuts) 

73181699 

Nuts of iron or steel other than stainless, with an inside diameter > 12 mm (excl. blind 
rivet nuts and self-locking nuts) 

73181900  Threaded articles, of iron or steel, n.e.s. 
73182100  Spring washers and other lock washers, of iron or steel 
73182200  Washers of iron or steel (excl. spring washers and other lock washers) 
73182400  Cotters and cotter pins, of iron or steel 
73182900  Non-threaded articles, of iron or steel 
73269040  Pallets and similar platforms for handling goods, of iron or steel 
73269050  Reels for cables, piping and the like, of iron or steel 
73269092  Articles of iron or steel, open-die forged, n.e.s. 
73269094  Articles of iron or steel, closed-die forged, n.e.s. 
73269096  Sintered articles of iron or steel, n.e.s. 

0.35 

0.61 
0.85 
0.55 
0.42 

0.49 

0.43 

0.76 

0.57 

0.47 

1.03 
1.24 
0.49 
0.66 
0.38 

0.46 

0.31 
0.72 
0.64 
2.05 
1.76 
0.83 
0.52 
0.53 
0.38 
0.41 

18