Steel export to Germany — ports, documents, transit time

CBAM: what a German importer needs from the mill

Since the definitive regime began, iron and steel entering the EU carries a carbon border adjustment, and the declarant — your company, not ours — is the one who reports and surrenders certificates. That turns an emissions figure into a commercial document, and it has to come from the producing mill.

What we supply with the shipment: the producing works, the route (electric arc or integrated), and the embedded emissions data the mill issues for the heat or the production period. Turkish flat and long production is largely electric arc furnace based, which is the reason the numbers usually compare well against integrated supply from further east.

What we cannot do is declare on your behalf. Ask for the emissions data at enquiry stage rather than at the border: a mill that has to produce it retrospectively takes weeks.

Steel is not an A.TR product — the certificate is EUR.1

This catches new buyers regularly. The EU–Turkey customs union covers industrial goods and moves them on an A.TR movement certificate, but coal and steel were excluded from it and sit under a separate free trade agreement instead. Steel therefore travels on a EUR.1 movement certificate or an invoice declaration proving Turkish origin.

The practical consequences are the same — preferential entry — but the paperwork is not interchangeable. A consignment presented with an A.TR for a steel tariff heading will be queried, and the correction costs days at the border rather than minutes at the desk.

We issue EUR.1 with every EU consignment as standard and state the tariff heading on the invoice so the classification is not left to the clearing agent.

Safeguard quota: why the arrival date matters

The EU steel safeguard runs as tariff-rate quotas by product category and country of origin, with an out-of-quota duty of 25 %. Quotas open at the start of each quarter and the popular categories — hot-rolled flat, hollow sections, coated sheet — can exhaust within days of opening in a strong quarter.

That makes the customs clearance date, not the order date, the one that decides the duty. Two identical containers shipped a week apart can clear at 0 % and 25 %. Where the volume justifies it, we schedule sailings against the quarter opening and say so on the order confirmation.

• Check the category quota balance before fixing the sailing, not after.
• A vessel arriving in the last week of a quarter is the highest-risk booking of the year.
• Truck consignments clear faster and in smaller lots, which spreads the exposure.
• The duty falls on the importer of record — the exposure is yours, so the timing has to be agreed in writing.

EN 1090 and CE marking on fabricated steel

Structural components placed on the German market need CE marking under EN 1090-1 with a declaration of performance, and the execution class in the drawing decides how much testing sits behind it. Plain mill products — coil, plate, sections, tube — do not carry CE marking themselves; they carry EN 10204 3.1 certificates, and the fabricator's own factory production control covers the rest.

For sandwich panel the reference is EN 14509, which does carry CE marking as a product, with a declared fire class and thermal transmittance. Where a German project specifies a panel by U-value and fire class, those are the two numbers we confirm in writing before the order rather than after delivery.