CBAM for screws and nuts since 2026
Screws, nuts, bolts, rivets and washers of iron or steel fall under CN heading 7318 and therefore under the Carbon Border Adjustment Mechanism CBAM. The definitive period has applied since 1 January 2026. Anyone importing more than 50 tonnes of CBAM goods per year needs the status of an authorised CBAM declarant and must buy certificates from 2027.
Timo Waldhoff
Managing Director
Short answer
- CN 7318 (screws, bolts, nuts, rivets, washers of iron or steel) is on the list of goods in the CBAM Regulation.
- The obligations fall on the importer, that is the person who lodges the customs declaration for release for free circulation.
- Below 50 tonnes of CBAM goods per importer and calendar year, the de minimis exemption applies.
- The first CBAM declaration, for 2026, is due by 30 September 2027, and certificates are available from February 2027.
- The legal position in this article is as at 26 September 2026.
For standard parts made of steel, CBAM has no longer been a side issue since the start of the year. Heading 7318 is on the list of goods in the Regulation, so it covers exactly the screws, nuts and washers that you handle in purchasing every day. Whether this creates obligations for you yourself depends on two questions: who imports the goods, and how many tonnes add up over the year?
The legal position in this article is as at 26 September 2026. It is based on the pages of the German Emissions Trading Authority (DEHSt), German Customs (Zoll) and the European Commission. This article does not replace legal or customs advice.
What CBAM is and since when it applies
CBAM is the EU's carbon border adjustment system, in full the Carbon Border Adjustment Mechanism. Its legal basis is Regulation (EU) 2023/956, in force since 17 May 2023. It is intended to give imported goods a price that reflects the emissions from their production. The system complements the EU Emissions Trading System (EU ETS).
During the transitional period from 1 October 2023 to 31 December 2025, quarterly reports were sufficient. Since 1 January 2026 the Regulation has applied in full, and the reporting obligation has become a payment obligation. In Germany the competent authority is the DEHSt at the German Environment Agency (Umweltbundesamt).
Which fasteners fall under CBAM
Fasteners made of iron, steel and aluminium are covered, and the decisive factor in each case is the CN code. The Regulation covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Annex I specifies via the CN code which goods are affected in detail. For fasteners, these three headings come into question:
| CN heading | Goods according to the CBAM list | Affects, for example |
|---|---|---|
| 7318 | Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel | Standard parts such as hexagon head screws, nuts, washers, set screws, rivets, also in stainless steel |
| 7326 | Other articles of iron or steel | Steel parts not classified under a more specific heading, depending on classification |
| 7616 | Other articles of aluminium | Fasteners and parts made of aluminium |
Source: DEHSt, overview of the sectors and products covered by CBAM, last updated 6 February 2026.
Materials outside the six sectors, such as brass or plastic, are not covered. For parts made to drawing, the customs tariff number decides, not the designation on the drawing. In the German Electronic Customs Tariff (EZT) you can recognise affected goods by TARIC measure type 775.
Who bears the obligations
The obligations lie with the importer. The importer is the person who lodges the customs declaration for release for free circulation in their own name. According to German Customs, other customs procedures such as customs warehousing or transit are not covered.
The DEHSt distinguishes three cases. If you are established in the EU and lodge the declaration yourself, you need the status of an authorised CBAM declarant yourself. If the importer is established outside the EU, an indirect customs representative must import, and the obligations apply to the representative. According to German Customs, the representative needs the authorisation even if the importer stays below the 50-tonne threshold.
The third case lies in between: you are established in the EU but import via an indirect customs representative. Then either you or the representative fulfil the obligations. Who takes this on is agreed between the two of you internally, and the representative may refuse to take it on.
In purchasing, this comes down to one question, namely who clears the goods through customs. If you buy fasteners from a supplier established in the EU who declares the import themselves, you are not the importer of these goods within the meaning of the Regulation. If you order directly from a third country and clear the goods yourself, you are.
The 50-tonne threshold
Anyone importing no more than 50 tonnes of CBAM goods in a calendar year is exempt from the obligations. This mass-based exemption has existed since 2026 and is set out in Article 2a of the Regulation. What counts is the net mass. Electricity and hydrogen are not included.
The threshold applies per importer and calendar year, across all CN codes combined. Anyone importing 30 tonnes of screws and 25 tonnes of steel tubes is therefore above it. The exemption is indicated in the customs declaration with document code Y137.
The authorisation must be in place before the threshold is exceeded. According to the DEHSt, anyone who exceeds 50 tonnes without authorisation can no longer import CBAM goods until authorised, and penalty proceedings may follow. Importers who had submitted their application by 31 March 2026 may continue to import provisionally until a decision is made (Article 17(7a), code Y238).
Goods originating in Norway, Iceland, Liechtenstein and Switzerland are also exempt. The EU Emissions Trading System applies there or is linked to it.
Deadlines and obligations in the definitive period
The first CBAM declaration is due by 30 September 2027 and covers the import year 2026. Certificates can be bought from February 2027. The overview shows which obligation applies when:
| Obligation | Deadline or point in time | Basis |
|---|---|---|
| Authorisation as a CBAM declarant | before exceeding 50 tonnes in the calendar year | Art. 4, 5, 17 |
| Entry in the customs declaration | for every import: Y128 and CBAM account number, Y137 if exempt | German Customs |
| Purchase of CBAM certificates | from February 2027 via the common central platform in the CBAM Registry | DEHSt |
| Holding certificates | from 2027 at the end of each quarter, at least 50 percent of the embedded emissions since the start of the year | Art. 22 |
| CBAM declaration for the previous year | annually by 30 September, for the first time by 30 September 2027 for 2026 | Art. 6 |
| Surrender of certificates | annually by 30 September, matching the declaration | Art. 22 |
Sources: DEHSt, obligations in the CBAM definitive period from 2026 (last updated 12 March 2026), and German Customs, general information on CBAM, accessed on 26 September 2026.
There is currently still one catch: according to the DEHSt, declarations could most recently not be created in the CBAM Registry, and this is expected to become possible from the fourth quarter of 2026.
How the costs arise
The costs result from the embedded emissions of the goods, that is the emissions from their production. They determine the number of certificates you have to surrender. The price of a certificate depends on the price of emission allowances in the EU ETS.
There are two ways to determine the embedded emissions. Either the manufacturer supplies actual values that have been recorded using the prescribed methods and verified by an accredited verifier. Or the importer uses the default values set by the European Commission in Implementing Regulation (EU) 2025/2621. A carbon price actually paid in the country of origin can be deducted under Article 9.
For purchasing, this means that every plant outside the EU will be asked one more question in future. Are verified emission values available, and are they provided via the portal in the CBAM Registry?
What buyers should check now
Five questions for assessment:
- Which of your bought-in parts fall under CN headings 7318, 7326 or 7616, and who declares their import?
- How many tonnes of CBAM goods do you import yourself in a calendar year, across all product groups combined?
- Are you above 50 tonnes or close to it: has the authorisation been applied for or granted?
- Do you import via an indirect customs representative: is it agreed in writing who takes on the CBAM obligations?
- Can your plants supply verified emission values, or are you working with default values?
How NORM+DREH handles this. We source parts made to drawing, special parts and DIN/ISO parts from partner plants in China, Taiwan and Turkey, keep them in stock in Germany and deliver on call-off. Depending on the product, import handling also includes the origin and customs documentation and the CBAM-relevant documents. We set out in writing before the first delivery how the customs roles are allocated for your delivery. You can read how the process works in detail on the page Global sourcing.
Frequently asked questions about CBAM for fasteners
Do screws fall under CBAM?
Yes, if they are made of iron or steel. CN heading 7318, with screws, bolts, nuts, rivets and washers, is on the CBAM list of goods. Fasteners made of aluminium come under heading 7616, which is also covered.
Do I have to comply with CBAM if I buy screws from a German distributor?
That depends on who lodges the customs declaration for release for free circulation. If your supplier established in the EU declares the import themselves, you are not the importer of these goods. If in doubt, ask who clears the goods through customs in your supply chain.
What does the 50-tonne threshold mean under CBAM?
Anyone importing no more than 50 tonnes of CBAM goods in total in a calendar year is exempt from the obligations. The count is per importer, across all affected CN codes.
When is the first CBAM declaration due?
By 30 September 2027 for the import year 2026. After that, by 30 September each year for the previous year.
From when can CBAM certificates be bought?
From February 2027 via the common central platform in the CBAM Registry. The price is based on the price of emission allowances in the EU Emissions Trading System.