CN Codes for CBAM Goods: What EU Importers Must Know

The European Union’s new novel climate policy, known as the Carbon Border Adjustment Mechanism (CBAM), aims to “level the playing field” between domestic producers and foreign manufacturers from areas with lower carbon prices.

CBAM aims to prevent carbon leakage and support the EU in achieving its decarbonisation goals by imposing a carbon cost on imports.

The foundation of CBAM is the Combined Nomenclature (CN) codes, which are standardised identifiers that identify which goods are subject to the regulation.

Learn more about CBAM with our detailed guide: Click here!

What are CN codes, HS codes, and Taric codes?

To ensure compliance with the CBAM, importers must understand the system of goods classification in the EU, specifically through HS, CN and TARIC codes. 

HS codes (6 digits)

The Harmonised System (HS) is a goods classification system recognised worldwide, used by over 200 countries. It’s 6 digits broadly define the categories of the goods. 

For example:

  • 7207.11 = Semi-finished products of iron or non-alloy steel

CN codes (8 digits)

The Combined Nomenclature (CN) adds two digits to the HS code, creating an 8-digit EU-specific code. These codes are then used to determine if the goods fall under the CBAM and calculate customs duties. 

For example: 

  • 7207.11.11 provides more detail about the type of steel.

TARIC codes (10 digits)

The TARIC code adds 2 more digits to the CN code, making it a 10-digit code. These codes provide information about customs duties, trade restrictions, and more, but they are not used in CBAM reporting. 

How are CN codes used for CBAM?

The Carbon Border Adjustment Mechanism (CBAM) is based on the idea of accurate product classification. CN codes are the primary tool used by the EU to determine whether imports are subject to this carbon pricing plan. 

Let’s understand it:

CBAM targets specific industries using CN codes

CBAM focuses on carbon-intensive industries such as

  • Cement
  • Iron and steel
  • Aluminium
  • Fertilisers
  • Electricity
  • Hydrogen (added in the transitional phase)

Each of these sectors contains several CN codes that identify the specific products covered. 

The full list of applicable CN codes is published in Annex I of the CBAM Regulation (Regulation (EU) 2023/956)

If your imported product matches one of these CN codes, it falls under CBAM, and that means reporting obligations apply.

How to find out whether your product is covered

The 8-digit CN code for your product must be compared to the list in CBAM’s Annex I. The product is deemed CBAM-covered if there is a match.

For businesses importing a large variety of products into the EU, this means:

  • Checking every imported item using its CN code.
  • Flag any products mentioned in CBAM Annex I.
  • Review the updated list regularly, as new products may be added over time.

If this classification step is done incorrectly, it may lead to non-compliance or expensive reporting errors.

CN codes are required for CBAM reporting

If a product is covered under the CBAM, the importer is required to disclose embedded emissions, or the greenhouse gases released during the product’s manufacture in the country of origin.

The emission data is reported as per the CN code of a product, which means each product category has its own emissions accounting.

This enables the EU to: 

  • Compare similar items 
  • Implement fair and uniform carbon pricing.
  • Promote greener industrial practices worldwide.

CN codes must be included in all emissions report submissions to the CBAM Registry, the official EU platform. 

CN codes reveal simple and complex goods

CN codes indicate whether a product is complex (i.e., items with several components) or simple (i.e., basic raw materials). This distinction is crucial:

  • Simple goods: Easier to calculate emissions because they go through fewer production phases. (e.g. steel billets)
  • Complex goods: May not be covered in the current phase of CBAM, but could be in the future (e.g. finished machinery)

The EU intends to broaden the scope of CBAM, which presently targets simple items. 

Knowing your product’s CN code makes it easier to determine whether it could be included in the future.

CBAM timeline: When does it all kick in?

Here’s a quick snapshot of CBAM’s rollout:

Phase What It Means
2023–2025 Transitional period: Reporting only, no carbon payments yet
From 2026 Full implementation: Carbon costs apply via CBAM certificates
Beyond 2026 Scope is likely to expand to more sectors and product types

Challenges importers face with CN classification

It’s not always easy to get the classification right. Importers often run into problems like:

  • Vague product descriptions
  • Conflicting classifications across suppliers
  • Lack of in-house customs expertise

To avoid these risks, many businesses consult customs experts or use digital classification tools such as iClassification, which ensures accurate CN codes.

Ensure CBAM compliance with CN codes

CBAM may feel complex, but everything starts with one key question: What’s the CN code of your product?

By correctly classifying your goods, regularly checking for updates, and understanding your emissions responsibilities, you can:

  • Avoid costly errors
  • Stay compliant with EU regulations
  • Contribute to a greener, fairer global trade system

Frequently Asked Questions

What is a CN code and how does it differ from an HS code and a TARIC code?

A CN code (Combined Nomenclature) is an 8-digit EU customs classification code that extends the globally used 6-digit Harmonised System (HS) code with two additional digits providing EU-specific detail. TARIC codes extend CN codes further to 10 digits, adding information about duties and trade restrictions. For CBAM purposes, the relevant code is the 8-digit CN code: it is used to determine which imports fall under the regulation and to report embedded emissions.

Which industries and product categories are subject to CBAM?

CBAM currently covers six carbon-intensive sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The specific products within each sector are identified by their CN codes, listed in Annex I of CBAM Regulation (EU) 2023/956. If an imported product's 8-digit CN code appears in Annex I, CBAM reporting obligations apply. The EU intends to expand the scope over time, so importers should monitor Annex I for updates regularly.

How do EU importers check whether their goods are subject to CBAM?

To determine CBAM applicability, identify the 8-digit CN code for each imported product and compare it against the list in Annex I of Regulation (EU) 2023/956. If the code matches, the goods are CBAM-covered and reporting obligations apply. Because product descriptions can be ambiguous and classifications can differ across suppliers, many importers use digital classification tools or customs experts to verify CN codes accurately before submitting CBAM reports.

What must importers include when reporting embedded emissions to the CBAM Registry?

When submitting CBAM reports to the EU's CBAM Registry, importers must report the embedded greenhouse gas emissions associated with each CBAM-covered product, linked to the product's CN code. Each CN code requires separate emissions accounting, allowing the EU to apply fair and consistent carbon pricing across comparable goods. Emissions must reflect those produced during manufacturing in the country of origin, calculated according to the methodology set out in the CBAM Regulation.

What is the difference between simple and complex goods under CBAM, and why does it matter?

Under CBAM, simple goods are basic materials such as steel billets that pass through fewer production stages, making their embedded emissions easier to calculate. Complex goods are multi-component finished products, such as machinery, which involve multiple production inputs. The current phase of CBAM primarily targets simple goods. However, the EU intends to expand the scope to include complex goods in future phases, so businesses importing finished manufactured products should monitor Annex I updates.

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