UNESID, the Spanish steel producers association, warned on July 31, 2026 that declaring large-diameter welded pipes as steel structures adds approximately €300 per tonne of CBAM liability. The statement, carried by Eurometal, the European steel distributors federation, is the first industry statement to put a euro figure on CN code classification risk as a CBAM cost driver. It concerns EU importers and customs brokers directly: the code entered on the customs declaration determines which default emission values apply to a consignment, and UNESID says some member states are accepting declarations that contradict a binding European Binding Tariff Information (EBTI) decision in force since August 2025.
What UNESID says is happening at EU customs
UNESID states that some EU member states are allowing large-diameter welded steel pipes to be declared as steel structures under CN code 7308 90 98, contrary to a binding EBTI decision in force since August 2025. The EBTI decision requires these products to be classified as large-diameter welded pipes, which fall under the pipe headings of Chapter 73 rather than under heading 7308. EBTI decisions are binding classification rulings issued through the EU's Binding Tariff Information system; they bind the customs authorities of all member states, not only the one that issued them, and serve as the EU-wide reference for how identical goods should be classified.
The association backs the warning with trade data. EU imports of steel structures reached approximately 1.6 million tonnes in 2025, a 2.5-fold increase since 2019, according to the UNESID figures reported by Eurometal. Alfonso Hidalgo de Calcerrada, UNESID's Economic Director, said that "correct product classification is a fundamental requirement for the uniform application of European legislation."
The dispute is not about CBAM scope. The CBAM steel CN codes list spans 54 codes across Chapters 72 and 73, and both heading 7305 (large-diameter welded pipes) and heading 7308 (structures and parts thereof) are covered goods. Pipes and structures also follow the same CBAM steel sector rules: direct emissions only, priced at the quarterly certificate price. What changes with the code is the emission figure attached to each tonne when no verified data accompanies it.
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Why the CN code moves the CBAM bill by about €300 per tonne
Correct CN classification determines which default emission values apply when actual emissions data is unavailable, and the default values for steel structures from China and Turkey run roughly 4 tCO₂ per tonne higher than the values for pipes. At the carbon price of about €80 per tonne of CO₂ that UNESID uses in its calculation, that 4-tonne gap translates to approximately €300 per tonne of additional CBAM liability for a consignment declared under the structures code.
The table below compares the two classification outcomes for the same physical product, as set out in the UNESID statement.
| Factor | Declared as large-diameter welded pipe | Declared as steel structure |
|---|---|---|
| CN classification | Pipe headings of Chapter 73, including 7305 | 7308 90 98 |
| Consistent with the binding EBTI decision | Yes, in force since August 2025 | No, per UNESID |
| Default emission values (China and Turkey origin) | Lower pipe values | Roughly 4 tCO₂/t higher |
| Additional CBAM liability at about €80/tCO₂ | None | Approximately €300 per tonne |
Default values are the fallback figures the CBAM default values system assigns per product and country of origin under Article 7(7) of Regulation (EU) 2023/956, set out in Implementing Regulation (EU) 2025/2621 with a 10 percent mark-up in 2026 that rises to 30 percent from 2028. The figures themselves moved this week as well: the Commission corrected the CBAM default values through IR 2026/1740, applying retroactively from January 1, 2026, which gives affected importers a second reason to recheck the numbers behind their liability estimates.
UNESID's €80 price assumption sits close to current market levels. The official Q2 2026 certificate price settled at €75.28/tCO₂e, and the Q3 CBAM certificate price is tracking above Q2 with EU ETS allowances holding a €79 to €86 band, so the €300 figure reflects roughly what the gap costs at today's prices rather than a stressed scenario.
What importers and customs brokers should do now
EU importers of welded pipe products need to verify their CN classification against the binding EBTI decision before their next customs declaration, because the declared code fixes which default values, and therefore which certificate liability, attaches to each consignment. Four steps close the exposure.
- Check the declared code. Run the product through the CN code lookup tool and confirm whether past consignments went in under a pipe heading or under 7308 90 98.
- Review the EBTI decision with your customs broker. A binding classification ruling in force since August 2025 outranks national declaration practice, even where a member state's customs office has accepted the structures code.
- Request actual emissions data from the supplier installation. Verified actual data replaces default values entirely, which removes the 4 tCO₂/t default gap from the calculation regardless of how the classification question resolves.
- Recalculate the 2026 certificate liability under the correct code. The full obligation chain, from authorization to declaration, is covered in the guide to CBAM compliance for steel importers.
Step 3 carries the most weight for large volumes. A 10,000-tonne annual flow of welded pipe caught on the wrong side of the classification line represents approximately €3 million in additional liability at UNESID's figures, before the 2026 CBAM factor of 2.5 percent is applied to scale the certificate obligation.
Uneven enforcement across member states
UNESID warns that inconsistent classification practice creates uneven enforcement, because the same consignment can carry approximately €300 per tonne more CBAM liability at one member state's border than at another's. The association describes classification as the difference between a competitive and a prohibitive import for the affected products, and its statement stresses that customs rules must be applied consistently across all EU member states.
The pattern also intersects with the Commission's circumvention watch. The CBAM anti-circumvention rules direct the Commission to monitor changes in trade patterns and practices that alter how goods are treated at the border, and a 2.5-fold rise in structures imports since 2019 is exactly the kind of trade-pattern shift that monitoring framework exists to examine. UNESID stops short of alleging deliberate circumvention; its complaint is addressed at member state customs practice rather than at importers.
Origin amplifies the stakes. Neither country named in the default value comparison currently operates a carbon price that qualifies for deduction under Article 9 of Regulation (EU) 2023/956, so the certificate liability calculated from the default values applies in full to both flows. The country profiles for CBAM China and CBAM Turkey cover the exposure and the state of each country's carbon pricing in detail.
What happens next
Every 2026 consignment declared under the wrong code feeds into the first annual CBAM declaration, due September 30, 2027, and into the certificate purchases that open on February 1, 2027. Importers who correct classification now, and who replace defaults with verified actual data where suppliers can provide it, remove the €300-per-tonne question before the liability crystallizes. Whether the Commission or national customs authorities respond to UNESID's call for uniform application remains open; the underlying mechanics do not change either way, because default values stay the fallback whenever a declaration arrives without actual emissions data attached.