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Requirement · SCP-05

Prefabricated buildings containing steel or aluminium are named in CBAM scope, carrying the embedded-emissions declaration and surrender duty into construction products.

Importers of prefabricated buildings containing steel or aluminium 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(21); Annex I, point (2) adding the 'Combined metal products' table to Annex I 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 one industry by name: Construction. as of 2026-08-14
  • Compliance is checked by accredited third party, per consignment. as of 2026-08-14
Addressee Importers of prefabricated buildings containing steel or aluminiumAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(21); Annex I, point (2) adding the 'Combined metal products' table to Annex I of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

importation of prefabricated buildings falling within CN ex- 9406 90 90 containing steel or aluminium

Obligation

Prefabricated buildings containing steel or aluminium are named in CBAM scope, carrying the embedded-emissions declaration and surrender duty into construction products.

Who is affected

Addressee
Importers of prefabricated buildings containing steel or aluminium
Class
Businesses
Sectors
Names Construction · Reaches Steel, Aluminium and metals
Applies
applies from 1 January 2028 per Art. 2

Burden drivers

D7 · D1 · D4 — 3 of 7 marks fire on this provision.

Source text

Verbatim

ex- 9406 90 90 – Prefabricated buildings, containing steel or aluminium

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