19 November 2025 – The table of Country Specific Embedded Emissions that “leaked” at the same time as the drafts for the CBAM benchmarks is, in our assessment, not reliable at this time. It should not be used for business decisions!
CBAM: Beware of the “Leaked” Country Specific Embedded Emissions
The initial excitement over the “leaked” CBAM benchmark documents was quickly followed by disillusionment. Not only we noticed irregularities in the Excel table listing the Country Specific Embedded Emissions (Country SEE). It must also be considered that the supposedly “leaked” Country SEE does not come from the same source as the drafts for the CBAM benchmarks.
We reviewed the values again on Monday and concluded that at least some parts of them are completely illogical and may contain errors.
WARNING: The circulating table of Country Specific Embedded Emissions must currently be treated with extreme caution and should not be included in any business decisions! The data in the table are not reliable!
Irregularities particularly in stainless steel
These irregularities are especially striking in stainless steel products from China, India, Indonesia, and Turkey – origins for which the EU already has high anti-dumping and anti-subsidy duties in place, or has extended them there through anti-circumvention investigations.
SEE significantly increased for origins under EU trade protection
The SEE values for these four origins are significantly increased compared to other countries, even though there is hardly any logically traceable evidence for these figures. Meanwhile, other origins, in some cases without their own stainless steel melting facilities, have been rated significantly lower, and in some cases even below the direct emissions of the supposedly “clean” EU stainless steel producers.
Report: Stainless Steel Carbon Footprint Comparison
The data in the table reminded us of a report commissioned by the EU steel lobby in 2022:
“304 Grade Stainless Steel Carbon Footprint Comparison EU, Indonesia and China“
The report, paid for by EUROFER, concluded at the time that CO2 emissions in Indonesia and China were significantly higher than in the EU.
Surprisingly, the EU stainless steel mills in that report were almost exactly at the total CO2 emissions (1.855 t/CO2e) that are now assumed in the SEE file only for the direct emissions (1.860 t/CO2e).
At the same time, the report ignored the fact that the CO2 emissions of the ferro-nickel alloys used in Europe for stainless steel production are almost 55% higher than those of the nickel pig iron predominantly used in Asia.
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Disclaimer: Many things here represent our opinion. Others are information from the Internet. We can therefore never claim to be correct or complete. And never base a business decision solely on the news you receive from us.
