EU CBAM and your fasteners: CN 7318 is in scope
The Carbon Border Adjustment Mechanism is not a future risk for fastener buyers — it is current law. Screws, bolts, nuts, washers and similar articles under CN heading 7318 have been CBAM goods since the transitional phase began on 1 October 2023, and financial obligations started on 1 January 2026.
The point most fastener suppliers get wrong
CN 7318 does not need any further amendment to be covered. It is already listed in Annex I of Regulation (EU) 2023/956, and the 2025 simplification package changed only the exemption threshold — not the product scope.
The obligation in one table
| Item | Position as of 2026 |
|---|---|
| Products in scope | CN 7318 — screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, washers (incl. spring washers). Our core product families sit here. |
| Legal obligation | Falls on the EU importer, who must hold Authorised CBAM Declarant (ACD) status; without it, goods can be stopped at customs. |
| Definitive regime | From 1 January 2026 — financial obligations apply (reporting-only phase ended 31 December 2025). |
| Small-consignment exemption | 50 tonnes per importer per calendar year, aggregated across all CBAM goods (Reg. (EU) 2025/2083). Below the threshold: no authorisation, no certificate surrender — but the correct customs code must still be declared. |
| Certificates | Not purchased during 2026; available on the EU registry from 1 February 2027, covering 2026 imports. |
| First annual declaration | 30 September 2027 for goods imported during 2026; annual thereafter. |
| Emission boundary | Iron and steel: direct emissions only — purchased electricity is not currently charged into the certificate obligation for steel. |
| Default values | Usable without supplier data, but carry a mark-up: +10 % (2026), +20 % (2027), +30 % (2028). Actual verified data removes the mark-up entirely. |
| Origin rule | CBAM follows the origin of the goods, not the seller — buying Chinese fasteners from a third-country distributor does not move the obligation. |
| Excluded origins | Iceland, Liechtenstein, Norway, Switzerland (EEA / linked ETS). |
| Further expansion | The Commission has proposed extending CBAM to further downstream steel categories from 1 January 2028 (including CN 7317 nails, 7312 rope and cable, 7320 springs). CN 7318 is unaffected because it is already in scope. |
What you receive from YITORCH
- CN code confirmation per product family, so your customs declaration is unambiguous.
- Production route disclosure: wire rod origin, mill, forming (cold heading / hot forging), heat treatment, coating — the inputs an emissions calculation needs.
- Energy and process data collected from the producing mill (electricity consumption, fuel, output mass) in the structure of the EU communication template.
- Precursor data support: supplier information on the wire rod (CN 7213) used for the fasteners, where the mill can provide it.
- Document pack: a plain-language note your declarant can attach, explaining what was measured, by whom and when.
What we cannot do — and why that is honest
We are not an authorised verifier, we do not file your CBAM declaration, and we do not sell certificates. Verification is performed by accredited verifiers appointed by the importer. Our role is to make sure your verifier has real numbers instead of default values.
The commercial argument, in one line
A Chinese supplier who cannot answer a CBAM question costs you a mark-up on every tonne. A supplier who can, saves your EU customer money on every shipment. That gap is why we publish this page instead of ignoring it.
Frequently asked questions
Is CBAM already in force for bolts and nuts?
Yes. CN 7318 has been within CBAM scope since 1 October 2023 (transitional, reporting only), and financial obligations began on 1 January 2026 with the definitive regime. It is not waiting for a future amendment.
We import less than 50 tonnes a year — does CBAM still apply?
Below 50 tonnes of aggregate CBAM goods per importer per calendar year, you are exempt from authorisation and certificate surrender. You must still declare the correct customs code. Note that the threshold is assessed at importer level across all CBAM goods combined, not per product or per supplier.
Do you provide actual emission values or default values?
We provide the mill-level energy and process data needed to build actual values. Where a mill cannot disclose the necessary figures, we tell you so explicitly rather than presenting an estimate as verified data.
Does buying from a non-Chinese distributor remove the obligation?
No. CBAM follows the origin of the goods, not the seller's location. If the steel originated in China, the obligation sits with the EU importer regardless of who invoiced it.
Need a compliance statement or document pack for your market?
Tell us the destination country and product family — we return the applicable route, required documents and lead time within 48 hours.