The heaviest CBAM good is not steel at all. Agglomerated iron ore — mostly pellets, fed into blast furnaces and direct reduction plants — is listed in Annex I to the CBAM Regulation under CN 2601 12 00. In 2025 the EU imported about 18.4 Mt of it, roughly 16 % of all CBAM tonnage.
| Origin | Pellets 2025 | Default 2026 | Benchmark | Exposure 2026 |
|---|---|---|---|---|
| Canada | 8.8 Mt | 0.099 | 0.086 | €11.0 m |
| Ukraine | 4.9 Mt | 0.132 | 0.086 | €19.5 m |
| Brazil | 2.7 Mt | 0.220 | 0.086 | €30.5 m |
| United States | 1.4 Mt | 0.748 | 0.086 | €76.8 m |
| Mexico | 334 kt | 0.143 | 0.086 | €1.6 m |
| United Kingdom | 90 kt | 0.308 | 0.086 | €1.7 m |
Why the cost is close to zero
Pelletising emits relatively little — the defaults are around 0.1 tCO₂e per tonne — and the benchmark is almost as high. After the 2026 free allocation adjustment, very little is left to pay: about €147 m across all suppliers, a few tens of cents per tonne. That changes as free allocation is phased out, but even in 2034 pellets remain one of the cheapest CBAM goods per tonne.
Pellets inflate CBAM tonnage statistics without moving the bill — worth remembering when ranking countries by volume.
Why they are covered anyway
Pellets are a precursor of iron and steel. Covering them keeps the chain consistent: an EU steelmaker using imported pellets and an exporter shipping finished steel are both measured against the same benchmarks. It also means pellet importers — often steel mills themselves — need authorised declarant status, even if the bill is small.