Home›Knowledge›Trade Compliance›EU — CBAM and CN 7318

Verified against official sources on 2026-10-09. This page is informational and is not customs, tax or legal advice. Whether you are an importer under CBAM, what must be declared and how embedded emissions are calculated are decided by Regulation (EU) 2023/956 as amended, by the customs authority of the member state of release for free circulation, and by the competent CBAM authority. Your broker or authorised declarant files; this page does not replace that. Re-open the EUR-Lex texts below before you rely on a date or a threshold.

Trade Compliance

EU CBAM and fasteners: is CN 7318 covered?

Yes. Heading 7318 — screws, bolts, nuts, washers including spring washers — is listed in Annex I to the CBAM Regulation under Iron and steel. The definitive-period obligations apply from 1 January 2026, but the first declaration and the first surrender of certificates are due by 30 September 2027 for calendar year 2026, and certificate sales only begin on 1 February 2027.

Bottom line

As of 2026-10-09, for importers, purchasing managers and EU customers buying fasteners into the European Union: screws, bolts, nuts and washers classified under CN 7318 are CBAM goods, because heading 7318 is listed in Annex I to Regulation (EU) 2023/956 under Iron and steel [1]. Definitive-period obligations apply from 1 January 2026 [3], the first declaration and the first certificate surrender are both due by 30 September 2027 for calendar year 2026 [4][5], and certificate sales start on 1 February 2027 [8]. An importer whose cumulative imports of iron and steel, aluminium, fertilisers and cement stay at or below 50 tonnes of net mass in a calendar year is exempt for that year [6].

Timeline

The dates below are of four different kinds — start of a reporting regime, start of an obligation, start of certificate sales, and the first filing deadline. Read them separately.

Date	What it is	What happens	Ref
1 October 2023	Transitional period begins	Reporting only, with no financial obligation.	[1]
1 January 2026	Definitive period applies	Only an authorised CBAM declarant may import Annex I goods; emissions data must be verifiable by an accredited verifier.	[3][9][10]
1 January 2027	Article 22(2) applies	Deferred provision, set by the 2025 amendment.	[8]
1 February 2027	Certificate sales begin	Article 20(1), (3), (4) and (5) apply from this date; before it, no certificates are sold.	[8]
30 September 2027	First declaration and first surrender	First CBAM declaration and first surrender of certificates, both for calendar year 2026.	[4][5]

The obligations and the money arrive at different times. Data collection starts with the 2026 calendar year even though nothing is paid before 2027, which is why suppliers are being asked for emissions figures now.

What is covered, and the 50-tonne test

Question	Answer on the regulation text	Ref
Goods in scope	CN 7318 in full: screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers including spring washers, of iron or steel. The greenhouse gas counted for this entry is carbon dioxide.	[1]
Is it only raw steel?	No. Annex I also lists finished headings such as 7307, 7308, 7318 and 7326.	[2]
Who is the importer	The person who submits the customs declaration for release for free circulation, including where an indirect customs representative does it.	[1][9]
Threshold	A single mass-based threshold of 50 tonnes of net mass, counted across iron and steel, aluminium, fertilisers and cement together, per importer per calendar year. Stay at or below it and you are exempt for that year; cross it and the obligations apply to all the embedded emissions of all those goods for that year.	[6]
Threshold exclusions	The threshold article does not apply to imports of electricity or hydrogen.	[7]
Where emissions come from	Embedded emissions follow actual production, not the country of export; the goods are in scope because they are imported into the EU customs territory.	[1]

The threshold is not per shipment and not per CN code. It is the cumulative net mass of all CBAM goods one importer brings in during a calendar year, across four sectors. For fasteners — a dense, heavy product — a few containers can move an importer across it, so the arithmetic is worth doing before the order is placed.

How to check your position — six steps

Confirm which legal person is the importer. Under the regulation it is the party submitting the customs declaration for release for free circulation, and an indirect customs representative changes who that is [1]. Where to check: the definitions in Regulation (EU) 2023/956 and your broker's mandate.
Confirm the CN code. The test is whether the goods fall under heading 7318 or another Annex I heading; the whole of 7318 is listed, so the subheading does not decide scope here [1][2]. Where to check: Annex I to the regulation on EUR-Lex, and the EU TARIC database for the code itself.
Total your net mass across the four sectors for the calendar year. Compare with 50 tonnes, counting iron and steel, aluminium, fertilisers and cement together [6]. Where to check: the amended Article 2a and Annex VII in Regulation (EU) 2025/2083.
If you are above the threshold, settle declarant status. From 1 January 2026 only an authorised CBAM declarant may import Annex I goods [3][9]. Where to check: Article 4 and the Article 36(2) commencement list, plus your national competent authority.
Ask the supplier for installation-level emissions data that can support verification. Article 8 verification and Article 18 accreditation of verifiers both apply from 1 January 2026 [10]. Default values exist in the scheme, but this page does not state their current figures — see What we could not confirm. Where to check: the implementing rules on embedded emissions; ask for data per installation and per production route.
Diarise 30 September 2027. That is the first declaration and the first surrender, both covering calendar year 2026 [4][5]. Where to check: Articles 6(1) and 22(1).

Common misreadings

Each claim circulates in summaries of the regulation. The right-hand column is what the text says.

What circulates	What the official text says
“CBAM is about raw steel only, not fasteners.”	Annex I lists finished headings as well: 7307, 7308, 7318 and 7326 [2]. Heading 7318 is quoted verbatim in the annex [1].
“Importers have to buy certificates in 2026.”	Certificate sales start on 1 February 2027, and the first surrender is due by 30 September 2027 [8][5]. The 2026 calendar year is a data year.
“CBAM is a customs duty paid at import.”	It is a declaration-and-surrender mechanism operated through the CBAM registry, not an import duty [4][5].
“The 50 tonnes is per shipment.”	It is cumulative per importer per calendar year, across iron and steel, aluminium, fertilisers and cement [6].
“Only the exporter has to worry about it.”	The obligation sits on the importer or authorised declarant, but it cannot be met without installation-level data that only the producer holds — which is why the data request reaches the fastener factory [9][10].

What we could not confirm

Open items from the source review, reproduced in full and unchanged as of 2026-10-09. None of them is stated as a fact anywhere on this page, and we deliberately quote no numbers for them.

Default values, and the Chinese grid emission factor. The current figures were not checked against the implementing act, so this page states none.
The embedded-emissions method for precursors and complex goods, including Annex IV and the related implementing rules. We did not verify these clause by clause.
Whether the proposed extension to downstream products — bringing finished goods that contain steel fasteners into scope — has been adopted. Its current status was not confirmed.
Mutual recognition with third-country schemes, for example the United Kingdom or Switzerland. Not verified.
Which data fields a supplier must provide, at the level of the implementing-act template. We did not verify the template.
How emissions are aggregated for goods processed or transhipped through a third country. The regulation keys on import, and embedded emissions follow actual production, but we did not read the aggregation rules for that case.

Sources

Official sources only, both on EUR-Lex. Opened and verified on 2026-10-09.

Ref	Source	Level
[1]	Regulation (EU) 2023/956 (CBAM), Annex I — Iron and steel, including 7318 (OJ L 130/52, 16 May 2023)	A
[2]	Same text, Annex I entries 7308 and 7326	A
[3]	Same text, Article 36(2)(b) as amended by Regulation (EU) 2025/2083: the definitive-period provisions apply from 1 January 2026	A
[4]	Same text, Article 6(1): first declaration in 2027 for the year 2026	A
[5]	Same text, Article 22(1): first surrender of certificates by 30 September 2027 for 2026	A
[6]	Regulation (EU) 2025/2083, new Article 2a and Annex VII: single mass-based threshold of 50 tonnes of net mass	A
[7]	Same text, Article 2a(4): the article does not apply to imports of electricity or hydrogen	A
[8]	Same text, amended Article 36(2): Article 20(1), (3), (4) and (5) apply from 1 February 2027; Article 22(2) from 1 January 2027	A
[9]	Regulation (EU) 2023/956, Article 4, within the 1 January 2026 commencement list	A
[10]	Regulation (EU) 2023/956, Article 8 (verification) and Article 18 (accreditation of verifiers), both from 1 January 2026	A

A = the regulation text itself. We read the consolidated text on EUR-Lex; the 2025 amendment is a separate act and both are linked above. Where a figure or date is not in one of these two documents, this page does not state it.