How do I demonstrate CO2 emissions per tonne of steel?

What you must concretely do

CO₂ emissions per tonne of steel is one of the figures that steel traders encounter most frequently: everyone knows that the figure will eventually become a permanent part of the product passport, but the calculation method that goes with it is not yet fixed. What is already happening in terms of content is CBAM: when steel is imported from countries outside the EU, the CO₂ emissions per tonne released during production are already being requested and calculated, albeit for a different purpose than the product passport. These two lines — CBAM now, the passport later — run partly in parallel and that is precisely where the confusion arises.

What is expected of you

Submitting CO₂ data on import (CBAM)

For steel imported from outside the EU, under Regulation (EU) 2023/956 (CBAM), the CO₂ emissions released during production must be reported and will eventually be settled financially. For a company with 10 to 100 employees that imports steel, this means in practice that data on embedded emissions are requested from the supplier outside the EU, and that this data is recorded per shipment. This is separate from the product passport: CBAM is a trade instrument at the border, the passport is a product data carrier that travels with the steel. What CBAM means for the import of steel is therefore a separate question, which does touch on the same underlying figures.

Following a calculation method as soon as it is fixed

For the product passport itself, on the basis of Article 39 of the ESPR (Regulation (EU) 2024/1781), values such as CO₂ emissions per tonne are determined according to a test, measurement or calculation method which the European Commission establishes per product group. For steel, that method does not yet exist. This does not mean there is nothing to do: it means that a company is well advised to already know which data form the basis of such a calculation, so that they do not have to be derived afterwards. Think of the scrap content, the type of furnace process, the source of the energy. Whoever now already records the scrap content in the melt, will have an important part of the calculation work already done, because scrap content is a core variable in most known CO₂ methodologies for steel.

Distinguishing between scope 1, 2 and 3

Even without a fixed method, it is practically valuable to distinguish between the emissions from your own production process (scope 1 and 2) and the emissions already contained in the purchased steel or ore (scope 3). For semi-finished products that are processed further, the question of what CO₂ burden is already in the purchased material is particularly relevant. That aligns with the question of whether ore origin is recorded in the product passport, because the origin of the raw material often determines the CO₂ profile — ore from a blast furnace process has a different composition than scrap in an electric arc furnace.

Keep data traceable to the source

Whatever calculation method is used, the underlying figures must be demonstrably sourced from somewhere: an energy invoice, a process record, a supplier's declaration. A CO₂ figure that is not traceable to a source is not sustainable in practice once a customer or supervisory authority asks about it.

Where things go wrong in practice

Several situations come up repeatedly among companies working on this topic:

• CBAM figures are confused with product passport figures. An importer thinks that the CO₂ declaration made for CBAM automatically also applies to the product passport. The scope and purpose of both regulations differ, and the calculation method for the passport has not yet been determined — adopting a CBAM figure one-to-one could result in an incorrect assessment later.
• An average figure is used instead of a figure per shipment or batch. An average CO₂ value over an entire year of production says little about one specific coil or steel ingot, whereas the passport will soon expect data per product or batch.
• Scrap content is not recorded separately. Because scrap has a major impact on CO₂ emissions per ton, missing or inaccurate recording of the scrap share is one of the most common gaps in the dossier.
• Suppliers outside the EU do not provide underlying data. On import, sometimes only a final figure is received without supporting documentation. As soon as that figure is checked, there is nothing to fall back on.
• Waiting until the method exists before recording anything. Because the delegated act has not yet been published, some companies are deferring all recording. This means that the basic data from before that date will be missing once the method does come into force.

What you can document

• An overview per shipment of the CO₂ data provided for CBAM, including the underlying source from the supplier.
• A record of the scrap share per melt or batch, to be combined with the recording of the scrap content in the melt.
• A dossier per supplier with the type of production process (blast furnace, electric furnace) and, if known, the energy source.
• Invoices or records of energy consumption per production line, as supporting evidence for a future calculation.
• A note with each batch on the origin of the raw material, in line with the recording of the origin of iron ore.
• A log of changes in production process or energy source, so that CO₂ figures can subsequently be linked to the correct period.

Once the European Commission publishes the delegated act for steel under Article 39 of the ESPR, the calculation method and the date on which it becomes mandatory will be provided here.