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Requirement · CALC-03

For iron and steel, aluminium and combined metal goods, derive the precursor mass from the content of input goods in the finished product rather than from a directly measured mass.

Operators of installations producing iron and steel, aluminium and combined metal goods must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

  • It is Art. 1(22); Annex II, point (2) replacing point 3 of Annex IV of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
  • The act gives its timing as: applies from 1 January 2028 per Art. 2. as of 2026-08-14
  • It names 2 industries by name: Steel and Aluminium. as of 2026-08-14
  • Compliance is checked by accredited third party, annual. as of 2026-08-14
Addressee Operators of installations producing iron and steel, aluminium and combined metal goodsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(22); Annex II, point (2) replacing point 3 of Annex IV of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

calculation of embedded emissions for goods in the Iron and Steel, Aluminium or Combined Metal Goods sections of Annex I

Obligation

For iron and steel, aluminium and combined metal goods, derive the precursor mass from the content of input goods in the finished product rather than from a directly measured mass.

Who is affected

Addressee
Operators of installations producing iron and steel, aluminium and combined metal goods
Class
Businesses
Sectors
Names Steel, Aluminium and metals · Reaches Automotive, Construction
Applies
applies from 1 January 2028 per Art. 2

Burden drivers

D4 — 1 of 7 marks fire on this provision.

Source text

Verbatim

However, for goods listed in sections ‘Iron and Steel’, ‘Aluminium’ and ‘Combined Metal Goods’ of Annex I, Mi is a function of the content of goods used as input materials (precursors) in the manufacturing of the good.

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