EU import data require product-level checks before attributing CBAM effects

BRUSSELS, Oct. 22, 2026 – Global exporters are competing for European industrial orders as tariffs, volatile energy costs and weak industrial demand interact with the European Union’s Carbon Border Adjustment Mechanism (CBAM). The latest official trade releases also show why changes in headline import values cannot be linked to CBAM without detailed analysis by product and country of origin.

Eurostat’s Oct. 16 release, covering August 2026, reported EU imports from outside the bloc of €228.0 billion. That was up 18.2% from €192.9 billion a year earlier. The EU’s monthly external trade deficit widened to €25.2 billion, compared with €7.5 billion in August 2025.

The figures cover all merchandise imports rather than only goods subject to CBAM. Movements in energy and machinery were described as substantial contributors to the overall trade balance. As a result, aggregate totals are not presented as evidence of changes in carbon-border-exposed import flows.

Aggregate partner growth does not show CBAM market-share shifts

China supplied €53.1 billion of EU imports in August, up 19.7% year on year. Imports from Türkiye reached €7.3 billion, an increase of 0.7%, while imports from India totalled €6.0 billion, up 18.3%. These partner-level changes are based on total merchandise trade.

The same partner figures include products outside CBAM’s scope. Customs values capture monetary value rather than physical tonnage or embedded emissions, so higher imports from a supplier do not automatically indicate a larger share of a specific covered product market.

A carbon-relevant comparison is therefore described as requiring product-level customs data and consistent origin definitions. It also requires separating goods already covered by CBAM from downstream products that have been proposed for inclusion.

CN-code precision for steel and aluminium coverage

For covered steel products, analysts are expected to aggregate the relevant eight-digit Combined Nomenclature (CN) codes listed in Annex I. The approach also requires consistent reporting definitions and a clear distinction between existing covered products and proposed downstream additions.

For aluminium, unwrought metal classified under CN 7601 cannot be combined indiscriminately with fabricated products classified under other headings. Calculating a weighted average customs price in euros per tonne is also described as requiring comparable import values and net mass.

The comparison framework is described as including the latest month, the preceding month, the corresponding month a year earlier and year-to-date figures. For each country of origin, it should report shares of extra-EU import tonnage and value, changes in those shares in percentage points, changes in tonnes and implied customs unit values.

Goods originating in Norway, Iceland, Liechtenstein and Switzerland require separate treatment because they benefit from relevant exemptions under the applicable CBAM framework. Broad Harmonized System chapter statistics can provide context but cannot replace an auditable product-level calculation.

Flat-steel competition shown in historical data

Historical trade figures are described as showing a closely contested European flat-steel import market. EUROFER’s European Steel in Figures 2026, using 2025 trade data, put EU imports of flat steel products at approximately 23.1 million tonnes.

Türkiye supplied 3.28 million tonnes, or 14.2% of the total, while South Korea supplied 3.24 million tonnes, or 14.0%. The figures are characterised as covering a broader group of finished flat products rather than a CN8-filtered total limited to CBAM-covered imports.

The historical totals are also noted as not establishing market shares for October 2026. The distinction is presented as important because historical product-group aggregates cannot be used directly to determine current competitive positions for individual exporters under the definitive carbon-border regime.

Steel import signals affected by inventories and safeguards

In its Oct. 1 market outlook, EUROFER reported that EU steel imports declined 5% in the first half of 2026 after an exceptional surge in late 2025. EUROFER also reported that exports fell 20% over the same period.

The reversal in imports is described as possibly linked to inventory accumulation ahead of the definitive CBAM phase. It is also described as consistent with weak steel demand, trade safeguards, price movements and logistics constraints.

Assigning the change to a single cause is described as requiring shipment-timing and product-level evidence rather than relying on broad trade movements alone.

Origin rules depend on processing location and routing

Comparisons between countries are described as complicated by where processing activities occur within supply chains. Steel slab imported from one country and converted into a finished product in another may acquire a different non-preferential origin from that of its precursor.

Customs statistics alone are described as not revealing the complete production and emissions chain needed for carbon liability assessments. Changes in customs unit values are also described as needing careful interpretation because they may reflect different grades, alloy content or delivery terms rather than shifts in underlying pricing pressure.

The distinction between customs origin and shipping route is described as becoming particularly important when suppliers establish distribution centres within the EU or neighbouring countries. A shipment invoiced through an intermediary does not automatically acquire that intermediary’s country of origin.

Reproducible unit-value calculations for supplier comparisons

A reproducible assessment is described as documenting the data-extraction date, exact CN8 selection, monthly coverage and provisional-data flags. It should also document the formula used to calculate unit values alongside other required inputs such as reported partner-origin fields and applicable non-preferential origin rules.

Treating a redistribution hub as the producing country is described as potentially distorting national market shares and leading to incorrect conclusions about which exporters gain business at others’ expense.

An example provided describes how an increase in a supplier’s share from 10% to 12% represents a gain of two percentage points rather than a 20-percentage-point increase. It also notes that rising customs value alongside declining tonnage indicates change in value per unit or product mix rather than necessarily greater physical market penetration.

Procurement decisions combine price with emissions data reliability

For European buyers sourcing from Serbia, Montenegro, Türkiye, India, China and Ukraine, procurement tests are described as increasingly combining competitive delivered prices with reliable emissions data and predictable supply. In 2026 these factors may influence purchasing decisions before definitive evidence becomes available on any CBAM-driven market-share shift.

Establishing competitive effects is described as requiring analysis at CN-code level with consistent treatment of physical volumes, customs values, product origin and applicable exemptions.

The latest aggregate trade figures are described as providing context for changes in the European import market but not establishing a ranking of CBAM winners and losers based on headline totals alone.

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