2026 EU CBAM Fence Import Guide: CN Codes, the 50-Tonne Threshold and Supplier Data

This article provides general information and a preliminary screening process only. It does not constitute customs, tax or legal advice. Final goods classification, import arrangements and CBAM compliance responsibility rest with the EU importer and its appointed adviser.

Whether the EU Carbon Border Adjustment Mechanism (CBAM) applies to a consignment of fencing products cannot be determined solely by whether the products are described as “steel fencing” or “aluminium fencing”.

First, the product’s actual 8-digit CN code at the time of import must be confirmed. That code must then be checked against Annex I to Regulation (EU) 2023/956. Broad headings such as 7308 and 7610 may be worth screening, but classification cannot be determined from the product name alone. The definitive phase of CBAM has applied since 1 January 2026.

For goods to which the mass threshold applies, the net mass of relevant CBAM goods must also be aggregated for the same importer and the same calendar year to determine whether it exceeds 50 tonnes. Buyers expecting to approach or exceed the threshold should prepare product, mass, installation and emissions information during the enquiry, contract and production stages, rather than attempting to retrieve data from suppliers only when the annual declaration is due.

Does EU CBAM Apply to Fence Imports? Pass Through Three Gates First

Gate One: Is the Actual 8-Digit CN Code Listed in Annex I?

The scope of CBAM is determined by the goods codes listed in the legislation, not by the marketing name used by the supplier.

Goods that are all described as “fencing” may be imported as:

• finished fence sections;
• welded mesh sheets or mesh rolls;
• steel or aluminium tube posts;
• aluminium profiles;
• fence gates;
• connectors;
• bolts and fasteners;
• unassembled complete systems.

These goods do not necessarily use the same CN code.

Gate Two: Does the Importer’s Aggregated Annual Net Mass Exceed 50 Tonnes?

The 50-tonne threshold is not calculated separately for each consignment, each supplier, each SKU or each CN code.

The correct basis is:

Same importer + same calendar year + aggregated net mass of relevant CBAM goods

The current single mass-based threshold applies in aggregate to relevant CBAM goods in the iron and steel, aluminium, cement and fertiliser sectors. Electricity and hydrogen are not covered by this mass-based exemption. Once an importer exceeds the threshold in a calendar year, the relevant obligations apply to all relevant imports in that year, not only to the portion above 50 tonnes.

Gate Three: Who Is Responsible for Authorisation, Declaration and Certificate Obligations?

After the applicable threshold is exceeded, the relevant responsibilities of the authorised CBAM declarant are normally assumed by the EU importer or, under an eligible arrangement, by an indirect customs representative.

A supplier in China or another non-EU country may assist in compiling product, production and emissions information, but cannot automatically replace the EU importer in meeting the statutory authorisation, annual declaration and CBAM certificate obligations. The European Commission has made clear that an importer exceeding the single 50-tonne threshold, or the corresponding indirect customs representative, must apply for authorised CBAM declarant status.

Product and import status
      ↓
Confirm the actual 8-digit CN code
      ↓
Check whether it is listed in Annex I
      ↓
Calculate the importer’s aggregated annual net mass
      ↓
Confirm the authorised CBAM declarant
      ↓
Choose default values or verified actual emission values
      ↓
Complete the annual declaration and certificate obligations

Important reminder: material names, catalogue names and supplier recommendations cannot replace formal goods classification.

CBAM Dates Fence Buyers Need to Watch in 2026

The European Commission has confirmed that the deadline for the first annual CBAM declaration and the corresponding surrender of certificates is 30 September 2027, covering imports made in 2026. Certificate prices for 2026 are calculated quarterly and will change to weekly calculation from 2027; certificates corresponding to 2026 imports will be available for purchase from February 2027.

This means that purchasing teams cannot wait until shortly before the 2027 declaration deadline to start requesting production, energy and emissions records for 2026 from suppliers.

Step One: Classify the Fence Products Before Assessing CBAM

The first question a fence importer must answer is not “Is the product made of steel?” but:

What is the correct 8-digit CN code for the goods as they enter the EU in their current state of packaging, separation, processing and assembly?

The EU Combined Nomenclature (CN) uses 8-digit codes. A 4-digit heading represents only a broad category of goods and cannot replace the final 8-digit classification.

Factors that may affect the classification of fencing goods include:

• whether the material is iron, non-alloy steel, stainless steel or aluminium;
• whether the product is wire, mesh, steel tube, profile, post, fence section or finished gate;
• whether the product has already been welded, drilled, bent or structurally worked;
• whether the goods are separate components or part of a complete system;
• which material or component gives a composite product its essential character;
• whether the product is assembled or unassembled at the time of import;
• the product’s actual structure, function and use.

Welded fence mesh panels, coiled wire, hollow steel tube posts, finished gates and a box of bolts should not use the same goods code merely because they are intended for the same fencing project.

What Are the Respective Roles of CN, TARIC, CLASS and BTI?

Combined Nomenclature (CN)

Used to determine the 8-digit classification of goods in the EU. Screening for CBAM scope should be based on the actual 8-digit CN code, rather than using only a 4-digit heading.

TARIC

Used to look up customs duties, trade defence instruments, quotas, restrictions and documentary measures associated with a goods code. TARIC includes information such as anti-dumping duties, countervailing duties and safeguard measures, but it does not contain the import VAT rates of Member States.

CLASS

CLASS can be used to find information relevant to the classification of goods in the EU, such as classification regulations, explanatory material, Commission conclusions and relevant case-law. It is suitable for supporting research, but ordinary search results or supplier recommendations do not in themselves constitute a binding classification decision.

Binding Tariff Information (BTI)

BTI is a binding goods-classification decision issued by an EU customs authority. A BTI decision is generally valid for three years, but it applies only to the specific goods and conditions described in the decision and may cease to be valid earlier following changes to legislation or classification rules.

CN Headings Worth Screening but Not Assuming

The table below is intended only to help importers and suppliers identify areas requiring further investigation. It is not formal classification advice for TOPSFENCE products.

The headings above are illustrative screening headings only. Confirm the currently valid 8-digit CN code on the basis of the actual state of the product at the time of import.

Step Two: Check the Current Scope of Annex I

After confirming the CN code, carry out the following four checks:

CBAM applies to goods originating in third countries that are listed in Annex I. A code used in a previous customs declaration should not be copied directly into a new order without verifying the product’s state and the current rules.

The supplier may assist by providing product drawings, material composition, processing methods and technical descriptions, but final classification should be confirmed by the EU importer and its customs adviser.

Step Three: Calculate the Annual 50-Tonne Threshold Correctly

The core basis for calculating the 50-tonne threshold is:

• the same importer;
• the same calendar year;
• relevant goods within the scope of Annex I;
• aggregated by net mass.

The threshold cannot be split in the following ways:

• 50 tonnes for each consignment;
• 50 tonnes for each supplier;
• 50 tonnes for each factory;
• 50 tonnes for each SKU;
• 50 tonnes for each CN code;
• separate 50-tonne allowances for steel and aluminium goods.

Under the current legislation, relevant goods in the iron and steel, aluminium, cement and fertiliser sectors use one aggregated mass-based threshold. This prevents importers from avoiding obligations by splitting consignments or suppliers.

Example: Exceeding 50 Tonnes Across Suppliers

An EU importer brings in the following goods during the same calendar year:

Assuming that the CN classifications of all three groups of goods have been confirmed and that all fall within the scope of Annex I, the importer’s aggregated annual net mass is 52 tonnes, which exceeds the 50-tonne threshold.

The threshold is not recalculated when the supplier, product model or shipping consignment changes.

Once the threshold is exceeded, the importer’s relevant obligations do not apply only to the two tonnes above 50 tonnes. They cover the embedded emissions in all relevant goods imported during that calendar year.

Importers expecting annual purchases to approach 50 tonnes should therefore address authorised CBAM declarant status, data collection and the allocation of internal responsibilities before the threshold is actually exceeded.

Step Four: Define the Responsibilities of Each Participant

CBAM requires collaboration among several parties, but their statutory roles cannot replace one another.

A non-EU fence supplier may assist in establishing the data chain, but should not use wording such as “we complete all CBAM compliance for the importer”.

Step Five: Choose Between Default Values and Actual Emission Values

When submitting the annual declaration, the EU importer may use default emission values or verified actual emissions data in accordance with the applicable rules.

Using Default Values

Default values are determined under EU rules and can reduce reliance on emissions data from a specific factory.

However, it should not simply be assumed that:

• default values will always be cheaper than actual values;
• all products can use default values indefinitely;
• a supplier can set its own “default value”;
• using default values removes the need to retain any product or import data.

The final reporting method should be chosen by the authorised CBAM declarant on the basis of the rules in force and the actual circumstances.

Using Actual Emission Values

Actual emission values normally require:

• a compliant monitoring method;
• complete energy, fuel, electricity and production records;
• a clearly defined installation and system boundary;
• appropriate calculation methods and emission factors;
• verification by a suitably qualified independent verifier.

The European Commission has made clear that, when actual emissions data are used, verification must be completed by an independent verifier accredited by a national accreditation body in an EU Member State.

Energy-consumption tables or carbon-emissions estimates prepared by the factory can form part of data preparation, but should not be described as “verified actual emissions data” until the applicable verification has been completed.

Verification generally concerns the installation and production process that produce the relevant goods, rather than merely checking a commercial invoice.

What Information Should EU Buyers Request From Fence Suppliers?

The specific fields should follow the European Commission’s current communication template and the requirements of the importer or its CBAM adviser.

A. Product and Consignment Identification Information

• product SKU or internal product number;
• product drawings, technical descriptions and photographs;
• material grade and material composition;
• the 8-digit CN code confirmed or provided by the importer;
• the net mass of each SKU;
• the net and gross mass of each consignment;
• commercial invoice and packing-list numbers;
• country of origin;
• shipping batch and production batch;
• the link between the product and the relevant production records.

B. Installation and Production Route

• legal name of the non-EU producer;
• address of the production installation;
• relevant production line or installation boundary;
• main production steps;
• production route for the product;
• output or activity level for the corresponding product during the reporting period;
• precursor materials used and their sources, where applicable;
• the production installation at which the last relevant processing step was completed.

C. Emissions and Monitoring Information

• direct emissions data;
• applicable indirect emissions data;
• fuel-use records;
• energy- and electricity-use records;
• monitoring method;
• emissions-calculation method;
• source of emission factors;
• the official EU communication template or operator’s emissions report;
• the independent verification report when actual values are used;
• the verifier and its accreditation information;
• evidence of a carbon price paid in the country of origin, where applicable.

D. Data Management and Access Rights

• who generates the data;
• who reviews the data;
• who approves and submits the data externally;
• the installation, product and time period to which the data relate;
• how missing values are handled;
• how versions of data amendments are retained;
• how an audit trail is created;
• whether the data are shared with designated declarants through O3CI;
• how access to commercially sensitive data is restricted;
• whether a confidentiality agreement is required.

Importers should, as far as possible, specify these requirements in the enquiry, purchase contract or data annex in advance, rather than asking the supplier to reconstruct historical records after production has been completed.

How Can O3CI Reduce Repeated Data Submissions by Suppliers?

O3CI is the function within the CBAM Registry for operators of installations outside the EU.

Operators of non-EU installations can upload installation and emissions data through O3CI and then authorise designated declarants to use them. This can reduce the need to send the same set of sensitive data separately to multiple EU customers. O3CI also supports access controls for commercially sensitive data.

The basic process may include:

• the non-EU operator prepares company-registration documents, representative-authority documents and identity documents;
• creates an individual EU Login account;
• sets up two-factor authentication;
• submits an O3CI access request;
• registers the relevant installation and emissions information;
• obtains the EORI provided by the importer or declarant;
• makes the relevant data available to the designated declarant;
• continues to retain versions, update records and verification documents.

The European Commission states that each O3CI user must register separately and that the declarant must provide its EORI to the non-EU supplier outside the Registry before it can retrieve the corresponding installation and emissions data from the system.

Points to note:

• an O3CI account is not an EU import authorisation;
• O3CI registration does not replace authorised CBAM declarant status;
• uploading data to O3CI does not automatically make unverified data compliant actual emission values;
• a supplier should not describe O3CI registration as “CBAM certification”.

How Can CBAM Cost Be Estimated Without Creating False Precision?

CBAM cost cannot be calculated simply as “certificate price × tonnes of fencing goods”.

A more reasonable conceptual formula is:

Preliminary CBAM cost exposure
= reportable embedded emissions
× applicable CBAM certificate price
− permitted carbon-price deductions and related adjustments

Final cost may be affected by:

• the quantity of imported goods;
• the embedded emissions of the product;
• whether default values or verified actual values are used;
• the certificate price corresponding to the quarter of import;
• the carbon price actually paid in the country of origin;
• applicable adjustments relating to EU free allocation.

The European Commission states that, if the importer can prove that a carbon price has already been paid during production of the goods, the corresponding amount may be deducted in accordance with the applicable rules.

Prices Published as at 14 August 2026

Certificate prices for 2026 are based on the weighted average of EU ETS auction clearing prices and are published quarterly. The price relates to carbon emissions, not to the physical mass of the fencing product.

Therefore, an apparently precise CBAM cost quotation for fencing should not be provided to a customer without reliable embedded-emissions data or an applicable default value.

CBAM Is Not the Same as Customs Duty, Import VAT or Anti-Dumping Duty

The same consignment of fencing products may be subject to several import costs and regulatory requirements, but each must be checked separately.

TARIC contains customs duties, anti-dumping measures, countervailing measures, safeguard measures and certain restrictions, but does not contain the VAT rates of Member States.

Incoterms can allocate transport, insurance, costs and risk between buyer and seller, but cannot automatically alter the person responsible under the CBAM legislation.

Accordingly, one uniform EU customs-duty rate should not be applied to all steel or aluminium fencing, and no uniform anti-dumping conclusion should be made for a category of fencing without checking the current TARIC measures.

Current Legislation and Future Scope-Extension Proposals Must Be Kept Separate

As at 14 August 2026, the current operating scope of CBAM includes specified goods in carbon-intensive sectors such as iron and steel, cement, fertilisers, aluminium, electricity and hydrogen. Whether a specific product is covered must still be determined by the codes in the current legislation and Annex I.

On 12 June 2026, the Council of the European Union adopted its negotiating position on strengthening CBAM, including extending its scope to certain downstream products and reinforcing anti-circumvention measures. That position still requires subsequent negotiations with the European Parliament and cannot be treated directly as final legislation that has entered fully into force.

Fence buyers should clearly distinguish between:

• goods that are already listed in Annex I;
• goods that are under discussion or negotiation and may be brought within scope in future.

The appearance of a fencing or downstream metal product in a policy proposal does not justify stating that it “has already been brought within CBAM”.

EU CBAM and UK CBAM Are Not the Same Mechanism

The United Kingdom plans to implement a separate CBAM from 1 January 2027.

The UK mechanism has its own commodity codes, scope, reporting method and implementing rules. The scope currently published by the UK Government includes specified goods in the aluminium, cement, fertiliser, hydrogen, and iron and steel sectors.

A classification or compliance assessment for imports into the EU cannot be copied directly into UK import operations.

This article discusses EU CBAM only.

How Does TOPSFENCE Prepare for EU Fence Enquiries?

When making an initial enquiry, buyers are advised to provide:

• the EU country of destination;
• product specifications and drawings;
• product photographs or assembly drawings;
• material composition;
• the estimated purchase quantity per consignment;
• the net mass of products per consignment;
• the estimated annual purchase volume;
• the 8-digit CN code currently used or being considered by the importer;
• whether the importer expects to exceed the annual 50-tonne threshold;
• whether default values or actual emissions data are planned;
• the data template required by the importer or its adviser;
• the deadline for product, production and emissions information.

Depending on the specific product, order and production route, TOPSFENCE can agree an appropriate information-compilation process with the buyer, for example:

• organising product specifications by SKU;
• providing material-composition information;
• providing product net mass;
• providing product drawings;
• compiling production-batch information;
• describing the relevant production steps;
• assisting in compiling available information using a template provided by the importer.

These capabilities should be published externally only where the corresponding records can be provided internally by the company.

The following wording should not be used without sufficient evidence:

• “CBAM-certified fencing”;
• “guarantees that the buyer complies with CBAM”;
• “CBAM-ready product”;
• “verified low-carbon fencing”;
• “confirmed carbon intensity per unit of product”;
• “the supplier can fulfil all CBAM obligations in place of the importer”.

Final CN classification, CBAM declaration, certificate purchase and certificate surrender responsibility continue to rest with the EU importer and its appointed adviser.

Common CBAM Errors in Fence Purchasing

1. Determining whether goods are covered solely from the name “steel fencing” or “aluminium fencing”.

   CBAM scope begins with the actual classification of the goods, not the product’s marketing name.

2. Treating a 4-digit heading as the final 8-digit CN code.

   A 4-digit heading can be used only for preliminary screening.

3. Assuming that all steel fencing falls under 7308.

   The product’s structure, use, state of processing and state at import may all affect classification.

4. Assuming that all aluminium fencing falls under 7610.

   Heading 7610 can only be a screening direction for certain products.

5. Treating 50 tonnes as a threshold for each consignment.

   The threshold is aggregated by importer and calendar year.

6. Calculating a separate 50 tonnes for each supplier or each type of goods.

   Changing supplier, SKU or consignment does not automatically reset the threshold.

7. Using gross mass instead of net mass.

   The applicable net-mass data should be used to calculate the threshold.

8. Addressing only the imports made after 50 tonnes has been exceeded.

   Once the threshold is exceeded, the relevant obligations cover all relevant imports in that calendar year.

9. Waiting until the annual declaration is due before requesting data from the supplier.

   Some production, energy and batch records may not be capable of accurate reconstruction a year later.

10. Describing an internal factory estimate as verified actual emissions.

    Actual emission values must meet the applicable independent-verification requirements.

11. Assuming that default values will always be cheaper.

    Final cost depends on the applicable default values and the factory’s actual emissions performance.

12. Treating O3CI registration as equivalent to importer authorisation.

    These are different Registry roles and processes.

13. Treating EU CBAM and UK CBAM as the same mechanism.

    The two mechanisms have different legal bases, codes and implementation dates.

14. Describing a proposal to extend the scope to downstream products as legislation already in force.

    A negotiating position and legislation that has formally entered into force must be clearly distinguished.

15. Assuming that Incoterms can remove an importer’s statutory obligations.

    Commercial contract terms cannot automatically alter the person responsible under the legislation.

Frequently Asked Questions

Does CBAM Apply to All Steel Fencing Imported Into the EU?

Not necessarily.

CBAM obligations may arise only where the actual CN code of the fencing product at import is listed in Annex I and the import arrangement meets the corresponding applicable conditions. This cannot be determined from the product name “steel fencing” alone.

Does Steel Fencing Always Use CN 7308?

Not necessarily.

Heading 7308 is worth screening for certain steel structural products, but the final code depends on the product’s material, structure, function, state of processing and presentation at the time of import.

Is Aluminium Fencing Always Classified Under 7610?

Not necessarily.

Heading 7610 can likewise only be a screening direction. Classification cannot be determined from the name “aluminium fencing” alone.

Is the 50-Tonne Threshold Calculated for Each Consignment?

No.

The threshold is based on the aggregated net mass of relevant CBAM goods for the same importer in the same calendar year, rather than being calculated separately for each consignment.

Must Steel and Aluminium Goods Be Aggregated Together?

For relevant CBAM goods in the iron and steel, aluminium, cement and fertiliser sectors to which the current single mass-based threshold applies, quantities must be aggregated annually by importer. Separate 50-tonne allowances cannot be set for steel and aluminium.

What Happens if the Importer Exceeds 50 Tonnes Only at the End of the Year?

Once the threshold is exceeded in that calendar year, the relevant obligations cover all relevant imports made in that year, not only the portion imported after the threshold was exceeded.

Businesses whose expected annual import volume may approach the threshold should therefore arrange authorisation, data collection and internal responsibilities in advance.

Who Is Responsible for Purchasing and Surrendering CBAM Certificates?

The authorised CBAM declarant normally purchases and surrenders the certificates in accordance with the applicable arrangement.

A non-EU fence producer cannot automatically assume this statutory obligation in place of the EU declarant.

Can a Non-EU Fence Supplier Decide to Use Default Values?

The final reporting method is decided by the authorised CBAM declarant responsible for the declaration in accordance with the applicable rules.

The supplier’s main task is to provide accurate and traceable product, production and emissions-related information to support the importer’s assessment.

Must a Supplier Register for O3CI?

Not necessarily.

O3CI can help operators of non-EU installations share installation and emissions data securely with designated declarants, but it is not a “certification” that every supplier must obtain in every circumstance.

Do Data in O3CI Automatically Constitute Verified Emissions Data?

No.

O3CI is a tool for registering and sharing information. Whether actual emissions data are compliant still depends on whether monitoring, calculation and independent verification meet the applicable rules.

Are EU CBAM and UK CBAM the Same System?

No.

UK CBAM is a separate mechanism planned to apply from 1 January 2027. The product scope and reporting assessment for EU CBAM cannot be applied directly to it.

Next Step: Prepare the Data Before Placing the Purchase Order

Do not wait until customs clearance or the annual declaration to discover that information is missing.

The following should be specified in advance in the enquiry or an annex to the purchase contract:

• product specifications and drawings;
• material composition;
• product net mass;
• EU country of destination;
• estimated annual purchase volume;
• current CN classification;
• responsibilities of the importer and indirect customs representative;
• the default-value or actual-emissions-data route;
• the data template to be completed by the supplier;
• the data reporting period and submission deadline;
• confidentiality and access arrangements for commercially sensitive data.

Planning to import fencing products into the EU?

Please provide TOPSFENCE with the product drawings, material composition, country of destination, estimated annual purchase volume and the CN classification currently used by the importer.

Depending on the specific product, order and production route, TOPSFENCE can assist in compiling the available product and manufacturing information for review by the EU importer or its CBAM adviser.

Final goods classification and CBAM compliance responsibility continue to rest with the EU importer and its appointed adviser.