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You import Brazilian steel slabs for re-rolling in Europe — and you need to calculate CBAM embedded emissions for semi-products that most compliance tools ignore

Brazil has doubled its slab exports to the EU. If you operate a rolling mill in Spain, Italy or Germany that transforms Brazilian slabs, billets or HRC into finished products, you are the importer under Regulation (EU) 2023/956. You need to calculate embedded emissions for every CN code under Chapter 72, including semi-finished products. Brazil has no carbon price — no Art. 9 deduction applies. CBAMCheck generates the 12-document dossier with Brazil default values already integrated. 100% in your browser.

Generate your CBAM dossier — €299Check which CN codes are in scope

€299 · One-time payment · 12 deliverables · 13,566 default values · Browser-side

Reg. (EU) 2023/956 · Mod. Reg. 2025/2083 · 13,566 default values (Reg. 2025/2621) · 120 countries · 285 CN codes · 100% browser-side

The numbers behind your Brazilian steel CBAM exposure

Brazil is one of the largest steel exporters to the EU, with a sharp increase in semi-finished products. As a European re-roller, the CBAM cost falls on you — not on the Brazilian mill. Understanding these figures before the first declaration deadline is the difference between budgeting correctly and absorbing an unplanned cost.

+114%
Growth in Brazilian slab exports to the EU (year-on-year)
2.583
tCO₂e/t — Brazil iron & steel default value (Reg. 2025/2621)
€299
One-time payment for the complete 12-deliverable dossier

Your CBAM compliance timeline as a Brazilian steel importer

The transitional reporting period ended 31 December 2025. The definitive period is now in effect. Here is the sequence of obligations that applies to your Brazilian steel imports under Regulation (EU) 2023/956.

1
Apply for authorised CBAM declarant status
Under Art. 5, you must obtain authorised CBAM declarant status before importing goods. Application via the CBAM registry. Required: EORI number, establishment in a Member State, no serious infringements of customs or tax legislation.
2
Calculate embedded emissions per CN code
Art. 7 + Annex IV. For each Brazilian steel product (slabs CN 7207, HRC CN 7208, rebar CN 7214, etc.), determine embedded emissions using actual data from your supplier or default values. For iron and steel products in Annex II, only direct emissions apply (Art. 7(1)).
3
Purchase CBAM certificates
Art. 22. CBAM certificates are sold by competent authorities from 1 February 2027. The price reflects the weekly average EU ETS auction price. You must hold enough certificates to cover embedded emissions at the time of declaration.
4
Submit CBAM declaration by 30 September 2027
Art. 6. The first annual CBAM declaration covers calendar year 2026. It must include: total quantity imported, total embedded emissions, number of certificates to surrender (adjusted for Art. 31 free allocation and Art. 9 carbon price — zero for Brazil).
5
Surrender certificates and retain records
Art. 22 + Art. 7(6). Surrender the required certificates via the CBAM registry. Retain all records — including verification reports — for four years after the declaration year.

Three mistakes European re-rollers make with Brazilian steel CBAM documentation

Mistake 1 — Ignoring semi-finished products in the CBAM scope

Slabs, billets and blooms under CN 7207 are explicitly listed in Annex I

Annex I of Regulation (EU) 2023/956 covers all of Chapter 72 of the Combined Nomenclature (with specific exceptions for ferro-alloys and scrap). Semi-finished products — slabs (CN 7207 11/12/19/20), billets, blooms — are fully in scope. A compliance tool that only covers finished products leaves your largest volume category uncalculated.

Mistake 2 — Applying a single emission factor to all steel products

Emission intensity varies by production route, product type and CN code

A Brazilian slab produced via BOF (basic oxygen furnace) from iron ore has a different emission profile than an EAF (electric arc furnace) product. The 13,566 default values in Implementing Regulation (EU) 2025/2621 differentiate by product and country. Applying a flat average underestimates or overestimates your CBAM certificate requirement.

Mistake 3 — Expecting a carbon price deduction for Brazilian steel

Brazil has no effective carbon price applicable under Art. 9

Art. 9 of Regulation (EU) 2023/956 allows a reduction in CBAM certificates if a carbon price has been effectively paid in the country of origin. Brazil has no operational ETS or carbon tax on steel production that qualifies. The full CBAM certificate cost applies without deduction. Budgeting with an assumed deduction creates a cost gap.

What you receive: 12 deliverables in a single ZIP file

CBAMCheck generates a complete compliance dossier — not a single generic report. Every document references the specific articles and annexes of Regulation (EU) 2023/956 it relates to. The dossier is generated in your browser from your input data. No data is transmitted to any server.

1

Scope Evaluation

Confirms which CN codes in your Brazilian steel imports fall under Annex I. Art. 2 + Annex I.

2

Embedded Emissions Calculation

Calculates tCO₂e per tonne for each CN code using default values or actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Number of certificates to purchase and estimated cost, adjusted for Art. 31 free allocation phase-out. Art. 22 + Art. 31.

4

Draft CBAM Declaration

Pre-structured declaration covering Art. 6(2) data fields: quantities, emissions, certificates, carbon price. Art. 6.

5

Carbon Price Documentation

Documents Art. 9 position — for Brazil: no applicable carbon price, full certificate obligation. Art. 9.

6

Annex V Records Template

Template for record-keeping obligations under Art. 7(6) and Annex V requirements.

7

Verification Preparation

Checklist and documentation aligned with Art. 8 and Annex VI verification principles.

8

Supplier Letter Template (English)

Formal letter to your Brazilian steel supplier requesting emission data per Annex IV requirements.

9

Compliance Calendar (.ics)

Importable calendar with all CBAM deadlines: declaration, certificate purchase, verification windows.

10

Executive Summary

One-page overview of your CBAM position — cost, timeline, risk — suitable for management reporting.

11

Interactive HTML Dashboard

Offline-capable dashboard with 2026–2032 projections reflecting the free allocation phase-out under Art. 31. Editable. Keeps working for 7 years.

12

Compliance Calendar Overview

Visual timeline of all obligations, deadlines and milestones from 2026 to 2034.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company's actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emission calculations.

Estimate your CBAM exposure for Brazilian steel

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What you pay for CBAM compliance: alternatives compared

Free toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoYes, HTML — works offline 7 yearsInside the platform
Supplier letterNoYes, in EnglishVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoNo (see Professional Pack)Yes

Choose your licence

1 Dossier
299 €
/ dossier

  • 10 professional PDF documents
  • Interactive HTML Dashboard (projection 2026–2032)
  • 13,566 official values integrated
  • Template letter in English for supplier
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
Professional Pack
1,999 €
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs representatives
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal asks for data. CBAMCheck calculates it.

● CBAMCHECK CALCULATES YOUR DATA

Embedded emissions, certificates, projections, documentation

CBAMCheck takes your import data — CN codes, tonnage, country of origin — and generates the 12-document dossier with emission calculations, certificate estimates, verification preparation and the interactive dashboard. Brazil default values from Reg. 2025/2621 are preloaded. You enter your figures; the tool does the rest.

∅ THE EU CBAM PORTAL ASKS FOR DATA

The CBAM registry collects — it does not calculate

The CBAM registry under Art. 14 is where you submit the declaration and surrender certificates. It does not calculate your embedded emissions, estimate your certificate requirement, or generate supporting documentation. You need to arrive at the portal with your numbers already computed and your records structured per Annex V.

What happens if you import Brazilian steel without surrendering CBAM certificates

Under Article 26 of Regulation (EU) 2023/956, penalties for non-compliance are calibrated to mirror — and in some cases exceed — the EU ETS penalty regime.

⚖️
Authorised declarant who fails to surrender certificates
EU ETS excess emissions penalty per missing certificate

Art. 26(1). The penalty is identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased pursuant to Art. 16(4). Payment of the penalty does not release you from surrendering the outstanding certificates (Art. 26(3)).

⚖️
Person who imports without authorisation
3× to 5× the standard penalty per certificate

Art. 26(2). If you introduce goods into the EU without authorised CBAM declarant status and without complying with CBAM obligations, the penalty is three to five times the standard rate. This applies per certificate that should have been surrendered.

⚖️
Importer exceeding the 50-tonne de minimis threshold
3× to 5× (Art. 26(2a))

Art. 26(2a) + Art. 2a. If you exceed the 50-tonne annual threshold without being an authorised CBAM declarant, the enhanced penalty applies to all emissions embedded in all goods imported that calendar year. A 10% tolerance may reduce the penalty, but the obligation is retroactive for the entire year.

Re-rolling Brazilian steel for multiple subsidiaries or clients? Professional Pack available.

If you manage CBAM compliance for multiple importing entities — as a trading house, customs representative or group compliance function — the Professional Pack gives you 70 complete dossiers with a single key. One dossier per importing company.

Request Professional Pack — 1,999 €
One-business-day response · No sales call · hello@solidwaretools.com

What CBAMCheck guarantees — and what it does not

CBAMCheck generates a structured document according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer / authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions — Brazilian steel imports and CBAM

Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours to keep.
Can I get a refund?
By activating the licence you give express consent for the immediate generation of digital content pursuant to Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical failures.
What if the regulation changes?
If the regulation changes during your licence period, you can regenerate the document with the updated version of the generator at no additional cost.
Does CBAMCheck cover semi-finished steel products like slabs and billets?
Yes. CBAMCheck covers all CN codes under Chapter 72 of the Combined Nomenclature listed in Annex I of Regulation (EU) 2023/956, including slabs, billets, blooms, hot-rolled coil, and other semi-finished products. The tool distinguishes between semi-finished and finished products for emission intensity calculations using the 13,566 default values from Implementing Regulation (EU) 2025/2621.
Brazil has no carbon price. Does that affect my CBAM cost?
Yes. Under Article 9 of Regulation (EU) 2023/956, importers can claim a reduction in CBAM certificates to be surrendered if a carbon price has been effectively paid in the country of origin. Brazil has no operational emissions trading system or carbon tax applicable to steel production. This means the full CBAM certificate cost applies to Brazilian steel imports, with no deduction under Art. 9.
Can I use actual emissions from my Brazilian supplier instead of default values?
Yes, under Article 7(2)(a) of Regulation (EU) 2023/956, you can use actual emissions verified in accordance with Article 8 and Annex VI. CBAMCheck generates the verification preparation documentation and a template letter in English to request emission data from your Brazilian supplier. If your supplier cannot provide verified data, default values with the regulatory mark-up apply under Article 7(2)(b) and Annex IV point 4.1.
What is the de minimis threshold for CBAM?
Under Article 2a of Regulation (EU) 2023/956 (as amended by Regulation (EU) 2025/2083), importers are exempted from CBAM obligations if the net mass of imported goods in a calendar year does not exceed 50 tonnes across all CN codes. If you exceed this threshold at any point during the year, CBAM obligations apply to all imports for that entire calendar year.
How does CBAMCheck handle the difference between direct and indirect emissions for steel?
For iron and steel products listed in Annex II of Regulation (EU) 2023/956, only direct emissions are taken into account pursuant to Article 7(1). CBAMCheck applies this rule automatically when calculating embedded emissions for CN codes under Chapter 72 and related finished products. The 13,566 default values from Implementing Regulation (EU) 2025/2621 already reflect this methodology.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

Your Brazilian steel imports need CBAM documentation. The dossier takes minutes, not months.

12 deliverables. Regulation (EU) 2023/956 in its current wording including Reg. 2025/2083. Brazil default values preloaded. Your data stays on your device. The ZIP you download is yours permanently.

299 € one-time
12 deliverables · 13,566 default values · No subscription · 100% browser-side
Generate your CBAM dossier — €299