Omar Hamdy.

Omar Hamdy, on the lender's side, in Cairo. Written in a personal capacity.

Data retrieved

CN 7211 23: Cold-rolled flat steel under 600 mm, under 0.25% carbon

An EU importer that declares this line on default figures uses 4.101 tCO2e per tonne for goods from Egypt, plus a mark-up. In 2025 the EU imported 2,427 tonnes of it from Egypt, worth EUR 1,751,551.

The default that applies to Egypt

Direct emissions: 4.101 tCO2e per tonne. Indirect emissions are not counted for this line (the table shows N/A), so the total is the direct figure.

Route indicator (C): Carbon Steel based on BF/BOF. It does not change the default. It decides which CBAM benchmark the importer uses for the deduction when it declares on defaults.

The mark-up schedule

YearMark-upDefault with mark-up, tCO2e per tonne
202610%4.5111
202720%4.9212
2028 onwards30%5.3313

For cement, iron and steel, aluminium and hydrogen the mark-up is 10% in 2026, 20% in 2027 and 30% from 2028. It applies to the total. The figures with the mark-up are my arithmetic; the binding figure is calculated in the CBAM Registry (2026/1740, recital 10).

Trade with the EU in 2025

Year
2025
Tonnes
2,427
Amount, EUR
1,751,551
Comext code and label
721123Flat-rolled products of iron or non-alloy steel, of a width of < 600 mm, simply cold-rolled "cold-reduced", not clad, plated or coated, containing by weight < 0,25% of carbon
Source
Eurostat Comext DS-045409, EU imports from Egypt, 2025; dataset updated 16 October 2026. Tonnes are Comext's quantity in 100 kg divided by 10, rounded.

The CN8 lines under this code with trade

CN8Comext labelTonnesEUR
7211 23 30Flat-rolled products of iron or non-alloy steel, of a width of < 600 mm and of a thickness of >= 0,35 mm, simply cold-rolled "cold-reduced", not clad, plated or coated, containing by weight < 0,25% of carbon (excl. electrical plate)1,7511,257,574
7211 23 80Flat-rolled products of iron or non-alloy steel, of a width of < 600 mm and of a thickness of < 0,35 mm, simply cold-rolled "cold-reduced", not clad, plated or coated, containing by weight < 0,25% of carbon (excl. electrical plate)676493,977

Comext sub-lines can differ slightly from the heading total, through rounding or confidential trade.

What this means in plain words

On default figures, each tonne shipped in 2026 is declared with 4.5111 tCO2e: the default of 4.101 times one plus the 10% mark-up. At the 2025 volume of 2,427 tonnes, that is about 10,948 tCO2e of embedded emissions on defaults (my arithmetic).

In 2028 the same tonne carries 5.3313 tCO2e, or about 12,939 tCO2e for the same volume.

The importer does not buy a certificate for every one of those tonnes: it deducts a benchmark amount that shrinks each year until 2034. The calculator on the CBAM for Egyptian steel rebar page does that step; this line is not among its lines, so use the default above in the same way.

Verified actual data from the plant replaces the default, and no mark-up is added to it.

Where to go next

Sources

  1. Commission Implementing Regulation (EU) 2026/1740 of 20 July 2026 correcting Implementing Regulation (EU) 2025/2621 as regards Annexes I and IV thereto: default figures, mark-ups and route indicators eur-lex.europa.eu
  2. European Commission, 'Default values definitive period (Excel format)', file 'DV correcting act_final update_06.08.xlsx' (version 2 of 6 August 2026, listed on the page as 10 August 2026; for information only, not legally binding): cross-check only; the regulation is binding taxation-customs.ec.europa.eu
  3. Commission Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions, Annex I, point 2, Table 1 'Mapping of CN codes to aggregated goods categories': aggregated goods categories eur-lex.europa.eu
  4. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, Annex I (goods in scope), as amended by Regulation (EU) 2025/2083: goods in scope eur-lex.europa.eu
  5. Eurostat Comext, dataset DS-045409 'EU trade since 1988 by HS2-4-6 and CN8', reporter EU, partner Egypt (EG), flow imports, indicators VALUE_IN_EUROS and QUANTITY_IN_100KG, annual 2025: 2025 trade, dataset updated 16 October 2026 ec.europa.eu
  6. European Commission, CBAM legislation and guidance (section 'Default values and benchmarks'): the Commission's page on default figures and benchmarks taxation-customs.ec.europa.eu

Dataset retrieved 2 November 2026.

Download the data, CSVDownload the data, JSON

Compilation by Omar Hamdy, licensed CC BY 4.0: reuse it with credit to Omar Hamdy, omarhamdy.com. The figures come from EU legal texts and the Commission's Excel file of defaults (© European Union, reuse authorised under Commission Decision 2011/833/EU) and from Eurostat Comext (© European Union, reuse with acknowledgement of the source under Eurostat's copyright notice). The electricity line is left out: its figures are IEA data under a non-commercial licence.

In a personal capacity. An explanation of published rules and data, not legal or tax advice for a specific shipment.