[{"data":1,"prerenderedAt":282},["ShallowReactive",2],{"blog:\u002Fblog\u002Fsteel-safeguard-2026-and-cbam":3},{"id":4,"title":5,"body":6,"date":267,"description":268,"extension":269,"hero":270,"heroAlt":270,"keywords":271,"meta":272,"navigation":273,"path":274,"readingMinutes":275,"seo":276,"stem":277,"tags":278,"__hash__":281},"blog\u002Fblog\u002Fsteel-safeguard-2026-and-cbam.md","The EU just halved the steel quota. Your CBAM position moved with it.",{"type":7,"value":8,"toc":257},"minimark",[9,18,50,65,68,71,76,83,86,89,92,96,99,106,109,112,116,127,130,140,150,165,169,172,178,185,196,200,210,216,222,228,232,235,246,249,252],[10,11,12,13,17],"p",{},"On ",[14,15,16],"strong",{},"1 July 2026"," the EU replaced its steel safeguard with a much tighter one\n(Regulation (EU) 2026\u002F1384). Three numbers from it have been widely reported:",[19,20,21,33,39],"ul",{},[22,23,24,25,28,29,32],"li",{},"the tariff-free quota fell ",[14,26,27],{},"47%",", to ",[14,30,31],{},"18,345,922 tonnes"," a year",[22,34,35,36],{},"the duty on anything above the quota ",[14,37,38],{},"doubled, from 25% to 50%",[22,40,41,42,45,46,49],{},"the scope grew from ",[14,43,44],{},"28 to 30"," product categories, and a ",[14,47,48],{},"\"melt and pour\""," rule now ties\norigin to where the steel was actually made, not where it was last processed",[10,51,52,53,56,57,60,61,64],{},"What has been reported far less is how the Commission arrived at that quota. It took the import\nshare the EU had in ",[14,54,55],{},"2013 — about 13%"," — and applied it to 2024 consumption. That is the stated\ndestination. For comparison, extra-EU steel was ",[14,58,59],{},"27% of EU consumption in 2024"," and averaged\naround ",[14,62,63],{},"30% in 2025"," (EUROFER).",[10,66,67],{},"So the measure is not a nudge. It is an explicit plan to cut third-country steel roughly in half.",[10,69,70],{},"And that is where it stops being only a trade story.",[72,73,75],"h2",{"id":74},"cbam-only-exists-at-the-border","CBAM only exists at the border",[10,77,78,79,82],{},"CBAM applies to goods ",[14,80,81],{},"imported"," into the EU. Steel from a mill inside the union is not in scope —\nnot a lower rate, not a simpler form: out of scope entirely, because its carbon is already priced\nby the EU ETS.",[10,84,85],{},"Which means the safeguard is, incidentally, a CBAM-reduction programme. Every tonne a buyer moves\nfrom a third country to an EU mill is a tonne that leaves the CBAM perimeter.",[10,87,88],{},"If your response to a 50% out-of-quota duty is to buy more inside the EU — and for many buyers it\nwill be — your CBAM exposure falls without you doing anything about CBAM.",[10,90,91],{},"That is the good news, and it is the last simple thing in this article.",[72,93,95],{"id":94},"moving-between-third-countries-is-not-neutral","Moving between third countries is not neutral",[10,97,98],{},"The other obvious response is to keep buying outside the EU but switch to whoever still has quota.\nThat works for the duty. It does not leave your carbon bill where it was.",[10,100,101,102,105],{},"CBAM default values are published ",[14,103,104],{},"per country of origin, per CN code, per year"," (Annex I,\nImplementing Regulation (EU) 2025\u002F2621). They are not a global average. Two mills making the same\nproduct to the same standard carry different figures depending on which country they sit in — that\nis the whole design of the instrument.",[10,107,108],{},"So a sourcing decision taken purely on duty and lead time silently reprices the carbon side. It can\ngo either way, and the two effects have nothing to do with each other: the country with spare quota\nis not systematically the country with the lower default value.",[10,110,111],{},"If you switch origin this year, the honest position is that you do not know what happened to your\nCBAM bill until you look up the new figure.",[72,113,115],{"id":114},"the-threshold-is-where-it-gets-sharp","The threshold is where it gets sharp",[10,117,118,119,122,123,126],{},"CBAM's entry point is a mass threshold: ",[14,120,121],{},"50 tonnes of net mass per importer per calendar year",",\ncumulative across ",[14,124,125],{},"all"," CBAM goods aggregated — iron and steel, aluminium, fertilisers and cement\ntogether (Art. 2a). Above it, everything applies. At or below it, you are exempt.",[10,128,129],{},"A buyer who cuts third-country steel hard enough can land under that line. Three things about that\nare worth knowing before anyone treats it as a plan.",[10,131,132,135,136,139],{},[14,133,134],{},"First: the exemption is not passive."," Below the threshold you must ",[14,137,138],{},"declare the exemption in the\ncustoms declaration"," itself. It is a positive act on every consignment, not a silence.",[10,141,142,145,146,149],{},[14,143,144],{},"Second: the year does not restart on 1 July."," The safeguard applied from the middle of the\ncalendar year. The CBAM threshold counts the ",[14,147,148],{},"whole"," year. Tonnes imported in the first half —\nunder the old, larger quota — still count. A buyer who stops entirely in July can still be over the\nline for 2026 on January-to-June volume alone.",[10,151,152,160,161,164],{},[14,153,154,155,159],{},"Third: the duty to apply for authorisation hangs on ",[156,157,158],"em",{},"expectation",", not outcome."," Art. 5(1b)\nrequires the application from an importer who ",[14,162,163],{},"expects"," to exceed. If you expected to cross and\nthen, because of the safeguard, did not, you were still right to apply. And the reverse case is the\none that bites: an importer who honestly did not expect to exceed and then did has no Art. 5(1b)\nduty — and is penalised under Art. 26(2a) anyway.",[72,166,168],{"id":167},"the-safety-valve-almost-nobody-mentions","The safety valve almost nobody mentions",[10,170,171],{},"Suppose you did expect to cross, applied, were authorised, and then bought so much less from outside\nthe EU that you finished the year below 50 tonnes. You are exempt. What about the certificates?",[10,173,174,177],{},[14,175,176],{},"Art. 23(2): they are all repurchased on request."," Not a proportion, not subject to a cap —\nwhoever bought on the expectation of exceeding and then did not exceed gets the lot bought back.",[10,179,180,181,184],{},"This is worth writing down now because it becomes live next year: certificate sales do not start\nuntil ",[14,182,183],{},"1 February 2027"," (Art. 20(1)). Nobody holds a 2026 certificate today. But 2027 is exactly\nthe year in which buyers will be sizing purchases against a quota regime they have only half a\nyear's experience of — and the provision that protects an over-cautious buyer is one paragraph in a\nregulation most people have never opened.",[10,186,187,188,191,192,195],{},"Note the shape of the year, though: certificates for 2026 may only be repurchased ",[14,189,190],{},"in 2027","\n(Art. 23(2a)), and whatever is left of that vintage is ",[14,193,194],{},"cancelled without compensation on\n1 November 2027"," (Art. 24(2)). The window is real but it is not wide.",[72,197,199],{"id":198},"what-to-do-this-week","What to do this week",[10,201,202,205,206,209],{},[14,203,204],{},"1. Pull your first-half tonnage."," Not the value, the ",[14,207,208],{},"net mass",", across every CBAM good, not\njust steel. That is the number the threshold is measured in, and it is already fixed for 2026 — no\nsourcing decision you take now can reduce it.",[10,211,212,215],{},[14,213,214],{},"2. Project the second half under the new duty."," If your buyers are already shifting to EU mills,\nyour extra-EU mass may be flattening. Add the two halves. Are you over 50 tonnes for the year, or not?",[10,217,218,221],{},[14,219,220],{},"3. If the answer changed, write down when it changed and why."," An importer whose expectation moved\nduring the year — in either direction — has a decision to document, not just a number to file. That\nis true whether the move takes you into scope or out of it.",[10,223,224,227],{},[14,225,226],{},"4. If you switched origin, re-check the default value."," Same CN code, different country, different\nfigure. It takes a minute and it is the single most likely place for this year's carbon bill to have\nmoved without anyone noticing.",[72,229,231],{"id":230},"two-regimes-one-shipment","Two regimes, one shipment",[10,233,234],{},"It is tempting to read the safeguard and CBAM as the same policy in two costumes — both make foreign\nsteel more expensive, both push toward European supply. They are not.",[10,236,237,238,241,242,245],{},"The safeguard is a ",[14,239,240],{},"quantity"," instrument: it cares how much comes in, and it stops caring once you\nare inside the quota. CBAM is a ",[14,243,244],{},"carbon"," instrument: it does not care how much you import, only\nwhat the production of it emitted, and it never stops applying above the threshold.",[10,247,248],{},"Optimise for one and you move inside the other. The buyers who come out of 2026 in good shape will\nbe the ones who noticed that the two questions have different answers — and asked both.",[250,251],"hr",{},[10,253,254],{},[156,255,256],{},"This article explains the rules as we read them; it is not legal advice. The safeguard is\nRegulation (EU) 2026\u002F1384, applicable from 1 July 2026. The CBAM provisions cited are in Regulation\n(EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083, with default values in Implementing\nRegulation (EU) 2025\u002F2621. Quota volumes and duty rates change; check the current tariff-rate quota\nposition with your customs agent before acting on any of it.",{"title":258,"searchDepth":259,"depth":259,"links":260},"",2,[261,262,263,264,265,266],{"id":74,"depth":259,"text":75},{"id":94,"depth":259,"text":95},{"id":114,"depth":259,"text":115},{"id":167,"depth":259,"text":168},{"id":198,"depth":259,"text":199},{"id":230,"depth":259,"text":231},"2026-09-03","Since 1 July 2026 the tariff-free steel quota is 47% smaller and the out-of-quota duty is 50%. Buying less from outside the EU lowers your carbon bill — and can quietly change whether CBAM applies to you at all.","md",null,"EU steel safeguard 2026, Regulation 2026\u002F1384, steel tariff rate quota, 50 percent out of quota duty, melt and pour, CBAM 50 tonnes threshold, CBAM sourcing, CBAM default values origin",{},true,"\u002Fblog\u002Fsteel-safeguard-2026-and-cbam",6,{"title":5,"description":268},"blog\u002Fsteel-safeguard-2026-and-cbam",[279,280],"compliance","am I affected","amlL0Xkww-U6gV2878OaxFj_G1fsLId8PDMJE_4fJAo",1790002811443]