CBAM and imported galvanizing kettles

Kettles are in scope

Galvanizing kettles classify under CN 7309 — reservoirs, tanks and vats of iron or steel, capacity over 300 litres, not fitted with mechanical or thermal equipment. CN 7309 sits in Chapter 73 and is within the scope of CBAM Regulation (EU) 2023/956, Annex I.

The 50-tonne threshold matters more here than in most sectors

An importer whose total annual imports of CBAM goods stay under 50 tonnes is exempt from CBAM obligations entirely.

A single large galvanizing kettle can weigh 20 to 85 tonnes. One kettle can take you over the threshold on its own.

If you are over it, the obligations fall on you as the importer (or on your indirect customs representative): authorised CBAM declarant status, a verified declaration of embedded emissions, and surrender of CBAM certificates priced against the EU ETS carbon price.

Why the emissions data your supplier gives you changes your cost

For iron and steel, only direct emissions are counted in the definitive period. Two calculation methods are accepted: a calculation-based method using activity data and laboratory-derived emission factors, or a mass balance method. Data must be at installation level.

Here is the part that affects your invoice. If your supplier cannot give you verified actual emissions data, you fall back on EU default values — and default values are deliberately set above typical actual performance. Using verified actual data instead can materially reduce your certificate cost.

So when you compare two quotations for the same kettle, the landed cost difference is not only the price. It is the price plus the CBAM certificates, and those depend on data your supplier either has or does not have.

Kettle weight is what drives your exposure, so it is worth sizing before you model the cost — the sizing guide gets you to a weight, and the product range lists weights by configuration. For what else we do and do not claim on the regulatory side, see standards and compliance.

Emissions data

We are working with our plate mill and our works to prepare installation-level embedded emissions data to the CBAM methodology, so that you can declare actual values rather than fall back on EU default values.

If you are evaluating a kettle purchase now and need to model your CBAM exposure, tell us and we will tell you exactly what we can and cannot supply today. We would rather give you an honest answer than a certificate that does not hold up at declaration.

Source: Regulation (EU) 2023/956 (CBAM), Annex I. Sector guidance for iron and steel. Figures current at time of writing; confirm with your customs representative.