CBAM definitive regime — Regulation (EU) 2023/956. After two years of transitional reporting (1 Oct 2023 – 31 Dec 2025), the EU Carbon Border Adjustment Mechanism entered its financial phase on 1 January 2026. EU importers of CBAM-covered goods — steel, aluminum, cement, fertiliser, hydrogen, electricity — must now surrender CBAM certificates equal to the embedded emissions of each consignment, priced against the weekly EU ETS auction average (€80–95/tCO₂e in Q1–Q2 2026 per EEX settlement data).
Scope mapping for WanLong's B2B catalogue. All stainless-steel flatware (HS 8211, 8215), aluminum foil trays (HS 7615), and stainless cookware (HS 7323) sit within CBAM Annex I. Bagasse, kraft, PET bottles, glass jars, and finished kitchen utensils without metal primary content are out of scope. The graph below summarises the pass-through cost for representative products at a €85/tCO₂e EU ETS price:
| Product | HS code | Embedded emission factor (tCO₂e/t) | CBAM levy / tonne @ €85 | Landed-cost impact |
|---|---|---|---|---|
| 304 stainless steel flatware (forged) | 8211.91 | 2.00 (EAF route) | ~€170 | +2.1% on FOB €8.10/kg |
| 430SS stamped spoons | 8215.99 | 2.40 (BOF route, China grid) | ~€204 | +3.8% on FOB €5.40/kg |
| Aluminum foil containers | 7615.10 | 1.70 (primary, coal-heavy grid) | ~€145 | +3.0% on FOB €4.85/kg |
| Aluminum foil (household roll, virgin) | 7607.11 | 2.20 (primary) | ~€187 | +3.5% on FOB €5.35/kg |
Methodology note. Emission factors above are conservative midpoints. EAF (electric arc furnace) stainless with ≥70% recycled scrap content sits around 0.5–0.8 tCO₂e/t — WanLong's 304 cutlery supply chain blends EAF billet with forged finishing, averaging 1.8–2.1 tCO₂e/t. BOF (basic oxygen furnace) primary-route stainless on the China grid, by contrast, is 2.2–2.6 tCO₂e/t. The EU Commission will publish "default values" in the CBAM registry by Q3 2026; until then, suppliers must submit installation-specific verified emission data, or risk the much-higher EU default value (3.5 tCO₂e/t for unalloyed steel).
What B2B buyers should request in 2026 contracts. (1) Ask your supplier for the mill-level installation-specific emission report (not the country default). (2) Negotiate an embedded-emission cap clause (≤ 2.0 tCO₂e/t for 304SS flatware) tied to a per-shipment CBAM-pass-through formula. (3) For aluminium products, prefer suppliers using hydro-powered smelters (≤ 0.5 tCO₂e/t) — Yunnan, Sichuan, and Guizhou grids qualify. (4) For 2027–2028, the EU will extend CBAM to downstream products (Article 31 review) including some finished cutlery sets; contract terms should pre-empt this.
What we are doing at WanLong. From 2026 Q2 we disclose installation-level emission data on every stainless and aluminium shipment to the EU (supplier mill name, route, EAF/BOF, grid region, and kg-CO₂e per kg-finished). The data is the same format that authorised CBAM declarants submit via the EU Commission transitional registry. Source: European Commission DG TAXUD CBAM portal; EEX EUA auction reports 2026; the IEA "Iron and Steel Technology Roadmap" 2025 update for embedded-emission benchmarks.
Source: Regulation (EU) 2023/956 (CBAM); EU Commission Implementing Regulation 2023/1773; EEX EUA auction data Q1–Q2 2026; IEA Iron and Steel Technology Roadmap (2025 update); CBAM Transitional Registry 2024-2025 data disclosures
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