EU CBAM for Aluminium Windows, Curtain Wall and Steel Structures Imported from China: What Annex I Lists and What an Importer Must Do

Annex I of the EU Carbon Border Adjustment Mechanism Regulation lists, among other goods, customs headings for aluminium structures and parts of structures, with the text naming “doors and windows and their frames” (heading 7610) and for iron or steel structures and parts of structures (heading 7308). Aluminium bars, rods and profiles (heading 7604), plates and sheets (7606), steel screws and bolts (7318) and other articles of iron or steel (7326) are on the same list. A buyer importing aluminium windows, steel structures or the profiles for them into the EU should therefore check each line of the bill of quantities against Annex I.

This article sets out what the Regulation text says, using the consolidated version of Regulation (EU) 2023/956 dated 20 October 2025 and the amending Regulation (EU) 2025/2083. It is a reading of the legal text for procurement planning, not legal or customs advice. Classification of a product is a customs decision, so your customs broker or the authority must confirm it, and you should check the current consolidated text on EUR-Lex before you order, because the Regulation can be amended again. This article covers the EU mechanism only. For the products themselves, see our guides to aluminium window and door manufacturers for UK and European projects and curtain wall manufacturers.

Which building products does Annex I list?

Article 2(1) says the Regulation applies to goods listed in Annex I originating in a third country when they are imported into the customs territory of the Union. Annex I identifies goods by Combined Nomenclature (CN) code. The entries below are taken from the aluminium and iron and steel tables of the consolidated text.

• 7610: aluminium structures (excluding prefabricated buildings of heading 9406) and parts of structures, with the text naming roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns, and aluminium plates, rods, profiles and tubes prepared for use in structures.
• 7604: aluminium bars, rods and profiles.
• 7606: aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm.
• 7308: iron or steel structures (excluding prefabricated buildings of heading 9406) and parts of structures, with the text naming roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns.
• 7306: other tubes, pipes and hollow profiles of iron or steel.
• 7318 and 7326: screws, bolts, nuts, rivets and washers of iron or steel, and other articles of iron or steel.

The list is longer than this. It also covers other aluminium headings such as tubes, containers and articles of aluminium, and other iron and steel headings. Check every product line, including fixings and accessories, against the full Annex I rather than relying on a product name such as “curtain wall” or “window”. Whether a given assembly falls under one of these headings depends on how it is classified for customs, and this article does not decide that.

When do the obligations apply?

The consolidated text sets the dates in its final article. It states that Article 2(2) and Articles 2a, 4, 6 to 9, 10a, 15, 19 and 21, Article 22(1) and 22(3) and Articles 23 to 27 and 31 apply from 1 January 2026, and that Article 20(1), (3), (4) and (5) apply from 1 February 2027.

• Authorised declarant: Article 4 says goods shall be imported into the customs territory of the Union only by an authorised CBAM declarant. Article 5(1) says any importer established in a Member State shall, before importing goods, apply for the status of authorised CBAM declarant.
• Annual declaration: Article 6(1) says that by 30 September of each year, and for the first time in 2027 for the year 2026, each authorised CBAM declarant shall submit a CBAM declaration for the preceding calendar year through the CBAM registry.
• Certificates: Article 20(1) says that from 1 February 2027 a Member State shall sell CBAM certificates on a common central platform to authorised CBAM declarants established in that Member State.

Article 3(15) defines the “importer” as the person lodging a customs declaration for release for free circulation in its own name and on its own behalf or, where an indirect customs representative lodges it, the person on whose behalf it is lodged. The sales terms of your supply contract therefore matter: decide before the order who will be the importer of record, because that party carries the CBAM obligations, not the factory in China.

Is there a small-quantity exemption?

Regulation (EU) 2025/2083 inserted Article 2a. It exempts an importer, including one with authorised declarant status, from the obligations under the Regulation where the net mass of the imported goods in a calendar year does not cumulatively exceed the single mass-based threshold. Annex VII sets that threshold at 50 tonnes of net mass, applied to the total net mass of goods under all CN codes aggregated per importer and per calendar year. The importer must declare the exemption in the relevant customs declaration.

Article 2a(2) adds that an importer who exceeds the threshold within the calendar year is subject to all obligations in respect of all emissions embedded in all goods imported in that year. For a project buying aluminium windows, structures and fixings in several shipments, the cumulative tonnage across all Annex I goods is what counts, so add up the whole year’s imports, not one container. Article 2a(3) provides for the Commission to assess the threshold each year by 30 April and to amend it by delegated act, so check the current value before you rely on it.

What the declaration has to contain

Article 6(2), as amended, requires the declaration to contain the total quantity of each type of goods imported in the preceding calendar year, in tonnes for goods other than electricity, including goods below the threshold, and the total embedded emissions in those goods, calculated in accordance with Article 7 and, where they are determined on the basis of actual emissions, verified. The amended Annex VI refers to identifying the installations where the input material (precursor) has been produced and the actual emissions from its production.

For a buyer, the practical point is that the data comes from the production chain in China. Recital 16 of Regulation 2025/2083 notes that the embedded emissions of some aluminium and steel goods are primarily determined by the emissions of the input materials, which means the origin of the metal matters as much as the factory that fabricates the window or the structure.

What to ask a China maker before you order

None of the following is a legal requirement placed on the maker by the Regulation. They are questions a buyer can put in the brief so that the importer can later complete a declaration. Put them in writing and keep the answers with the purchase order.

• Net mass per product line: the net mass in kilograms of each item and of each shipment, so the cumulative tonnage can be tracked against the threshold.
• Product description for classification: a clear description, drawings and materials list for each item, so the customs broker can decide the CN code.
• Metal origin: the name of the producer of the aluminium or steel used for each product line, to the extent the maker can give it, and whether the maker can name the installation where it was produced.
• Emissions data: whether the maker or its metal supplier can provide embedded-emissions data for the metal, in what form and on what timeline. If the answer is no, say so in the purchase file.
• Fixings and accessories: a separate line and weight for steel fixings and aluminium accessories supplied with the product.
• Documents: which shipping and production documents the maker will provide to support the importer’s file.

Planning the purchase

For an EU project, settle three things before the purchase order: who will be the importer and hold authorised declarant status; how the annual tonnage will be tracked; and what data the maker can supply about the metal. If you are unsure whether you cross the 50-tonne threshold, track the weight of every Annex I item through the year, including fixings.

The same project may also face duty questions that sit outside this Regulation. For another example of how a measure on goods from China is read from the original text, see our note on Canada’s anti-dumping measures on upholstered domestic seating.

Sources and how this article was checked

Read on 9 October 2026: Regulation (EU) 2023/956, consolidated text of 20 October 2025 (Articles 2, 2a, 3(15), 4, 5(1), 6, 20(1), the final article and Annex I), Regulation (EU) 2025/2083 of 8 October 2025 (Article 2a, Annex VII, recital 16, amended Annex VI). The Regulation can be amended after that date, so confirm the current text before you act. FBM Sourcing does not give legal or customs advice.

Questions buyers ask about CBAM and building products from China

Do aluminium windows from China fall under the EU CBAM?

Annex I lists heading 7610, which names aluminium doors and windows and their frames, and heading 7604 for aluminium profiles. Whether a particular product is classified under a listed heading is a customs decision, so ask your customs broker to confirm the code from drawings and a product description.

Who has to register as an authorised CBAM declarant?

Article 4 says goods may be imported only by an authorised CBAM declarant, and Article 5(1) says an importer established in a Member State must apply for that status before importing. The importer is the person lodging the customs declaration or the person on whose behalf it is lodged.

Is there a minimum quantity below which CBAM does not apply?

Article 2a and Annex VII set a single mass-based threshold of 50 tonnes of net mass per importer per calendar year across all CN codes in the Regulation. Exceeding it brings all imports of that year into scope, and the Commission can amend the threshold, so check the current value.

Does this article cover the United Kingdom?

No. It covers the EU Regulation only.

How does FBM Sourcing help with a project like this?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend. We do not give legal or customs advice.

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