The production route sets a steel CBAM bill. BF-BOF (blast furnace to basic oxygen furnace) steel carries the highest embedded emissions, DRI-EAF sits in between and scrap-based EAF is the lowest. The default CBAM benchmarks for hot-rolled flat steel (CN 7208) follow the same order: 1.370, 0.481 and 0.072 tonnes of CO2e a tonne. On default values, the country of origin’s table sets the default, and the route it assigns sets the benchmark.
Three routes, three emission levels
Steel reaches the market through three main production routes, and the route sets the embedded emissions that a CBAM bill prices.
| Route | How the steel is made | Embedded emissions | Default CBAM benchmark, CN 7208 (t CO2e a tonne) |
|---|---|---|---|
| BF-BOF | Blast furnace to basic oxygen furnace: iron ore reduced with coke, then converted | Highest | 1.370 |
| DRI-EAF | Direct reduced iron melted in an electric arc furnace (route D in Implementing Regulation (EU) 2025/2620) | Intermediate | 0.481 |
| Scrap-based EAF | Recycled scrap melted in an electric arc furnace | Lowest | 0.072 |
Implementing Regulation (EU) 2025/2620 sets these benchmarks per CN code in Column B of its Annex, and they apply from 1 January 2026. Answer 3.9 of the Commission’s CBAM Q&A of 15 October 2026 says revised benchmarks should apply to goods imported from 1 January 2027. They are to be based on the final EU ETS benchmarks for 2026 to 2030.
Iron and steel goods other than agglomerated iron ore (CN 2601 12 00) are Annex II goods under Regulation (EU) 2023/956, so only their direct emissions are priced. Emissions from the electricity used in the mill’s own production fall outside the CBAM figure. On actual data, a sintered ore precursor is the exception: its indirect emissions stay in, as set out in the answer on which CBAM sectors count indirect emissions.
Which route counts on default values?
On default values the plant’s own route does not count. Point 5.1 of the Annex to Implementing Regulation (EU) 2025/2620 uses the route that the default values regulation assigns to the country of origin. That regulation is Implementing Regulation (EU) 2025/2621, as corrected in July 2026, and for India it assigns BF-BOF, route (C), to CN 7208. An Indian electric arc furnace mill on defaults is therefore treated as a blast furnace mill on both sides of the calculation. It carries India’s default of 4.280 tonnes of CO2e a tonne and receives the 1.370 benchmark.
Route mix and the country tables
Each country table assigns one route per CN code. For CN 7208, the corrected tables give India 4.280, China 3.187 and Türkiye 2.428 tonnes of CO2e a tonne, all on route (C). Defaults on the same route still differ, because each is a national average. A few countries are assigned the scrap route (E) instead, such as Thailand at 1.920 and the Philippines at 0.740, and their deduction then uses the 0.072 benchmark. India’s full table appears in the answer on Indian steel default values.
When verified data replaces the default
Verified installation data puts the plant’s own route back into both numbers. What that does to a 500-tonne line by 2034 is worked in how verified emissions data replaces CBAM default values for steel. A route-specific position can be sized year by year in the CBAM cost calculator. A CBAM consulting service then calculates installation-level embedded emissions and prepares the CBAM report for verification by an accredited verifier.
Sources: Regulation (EU) 2023/956, consolidated · Implementing Regulation (EU) 2025/2547 · Implementing Regulation (EU) 2025/2620 · Implementing Regulation (EU) 2025/2621 · Implementing Regulation (EU) 2026/1740 · CBAM Questions and Answers, 15 October 2026