CBAM scrap and secondary metals: zero or near-zero embedded emissions
Scrap steel and secondary aluminium carry very low embedded emissions. How to document scrap share, what counts as scrap, and the mass-balance split.
Published 19/10/2026 · Facts checked on 2026-10-18
Answer box
Scrap and secondary metals carry very low embedded emissions under CBAM because the energy-intensive primary extraction and reduction steps have already happened in earlier life. Operators report scrap share through a mass-balance approach, splitting the finished product emissions between the primary and recycled portions.
Why scrap is near-zero
- Steel scrap goes back through an EAF (electric arc furnace), skipping blast-furnace / basic-oxygen-furnace iron reduction.
- Aluminium scrap goes back through a secondary smelter, skipping the very energy-intensive Hall-Héroult primary smelting step.
What counts as scrap
- Pre-consumer scrap: offcuts and process rejects from the mill itself or close suppliers.
- Post-consumer scrap: end-of-life recycled material.
- Clean vs. dirty scrap: cleanliness class affects the mass-balance factors.
Mass balance
The supplier declares:
- Tonnes of primary metal input.
- Tonnes of scrap input.
- Tonnes of finished product output.
The engine applies the EU rules to split the embedded emissions across the two input streams, so finished products with high scrap content get a low SEE and products with mostly primary input get a high SEE.
Common pitfalls
- Claiming 100 % scrap when the actual mix is 80/20.
- Not accounting for scrap processing energy (shredding, baling, pre-heat).
- Mixing clean and dirty scrap without tracking the split.