Treat ferrous waste and scrap, other than post-consumer scrap, as a precursor whose embedded emissions count towards the goods.

Operators and declarants using ferrous scrap as an input material 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(24); Annex III adding Annex VIII to 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 one industry by name: Steel. as of 2026-08-14
Compliance is checked by accredited third party, annual. as of 2026-08-14

Addressee Operators and declarants using ferrous scrap as an input materialAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(24); Annex III adding Annex VIII to Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor

Trigger

use of ferrous waste and scrap other than post-consumer scrap as an input material

Obligation

Treat ferrous waste and scrap, other than post-consumer scrap, as a precursor whose embedded emissions count towards the goods.

Who is affected

Addressee

Operators and declarants using ferrous scrap as an input material

Class

Businesses

Sectors

Names Steel · Reaches Waste and landfill

Applies

applies from 1 January 2028 per Art. 2

Burden drivers

D4 — 1 of 7 marks fire on this provision.

Source text

Verbatim

ex 7204 Ferrous waste and scrap; remelting scrap ingots and steel except post-consumer scrap

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