CBAM part 3: on default values, Kazakh rebar's bill reaches 72% of its import value

Kazakhstan is a smaller supplier of goods covered by the EU's carbon border adjustment mechanism (CBAM) than Türkiye or Ukraine, but its steel carries the heaviest default values of the three. Part 1 of this series set out the rules and Part 2 priced Türkiye's exposure. Part 3 does the same for Kazakhstan, using the same method: what the EU bought in 2025, and what an importer without verified emissions data from the Kazakh plant would owe per tonne in 2026.

What Kazakhstan sells

EU imports from Kazakhstan in 2025, according to Eurostat's Comext data, were led by unwrought aluminium (7601): 110,100 tonnes worth €274 million, down from 127,300 tonnes in 2024 and 1.7 per cent of EU imports by mass. Ferro-alloys (7202) came to 97,200 tonnes worth €143 million. Within them, high-carbon ferro-chromium (7202 41) amounted to 37,400 tonnes, 8.1 per cent of EU imports, and low-carbon ferro-chromium (7202 49) 9,500 tonnes, 16.2 per cent. Bars and rods (7214) rose to 166,900 tonnes worth €83 million, from 18,700 tonnes in 2024, or 7.3 per cent of EU imports, and semi-finished steel (7207) reached 84,500 tonnes. The EU recorded no cement imports from Kazakhstan.

The default arithmetic

The method follows Part 2. Defaults from the Commission's workbook carry a 10 per cent mark-up in 2026 under Implementing Regulation (EU) 2026/1740; the importer deducts 97.5 per cent of the Column B benchmark from the benchmarks workbook, as the Commission's Guidance No. 4 prescribes where defaults are used, with a correction factor fixed at 100 per cent. On our calculation, at the third-quarter certificate price of €82.32:

• Rebar (7214 20 00): a Kazakhstan default of 5.180 tonnes of CO2 equivalent per tonne against a benchmark of 1.364 leaves 4.37 certificates, about €360 a tonne. That equals 72 per cent of the average 2025 import value of €498 a tonne.
• Semi-finished steel (7207 11 14): the same default and benchmark give the same 4.37 certificates and €360, about 73 per cent of value.
• High-carbon ferro-chromium (7202 41): 2.350 against a 2026 benchmark of 1.142 leaves 1.47 certificates, about €121 a tonne, 7.7 per cent of value.
• Low-carbon ferro-chromium (7202 49): 2.870 against 1.142 leaves 2.04 certificates, about €168 a tonne, 7.2 per cent of value.
• Unwrought aluminium (7601): 1.870 against 1.423 leaves 0.67 certificates, about €55 a tonne, 2.2 per cent of value.

Applied to 2025 volumes, the bars alone would come to about €60 million, close to three-quarters of what the EU paid for them, and the semi-finished steel to about €30 million. Aluminium, the largest flow by value, would cost about €6 million. These are illustrations; volumes, product mix and prices will move.

Why steel is the outlier

Kazakhstan's steel defaults are above the fallback. For bars and semi-finished products the workbook sets 5.180 for Kazakhstan against 3.996 for countries without their own table, and 5.290 against 4.049 for hot-rolled flat products. Its aluminium default, 1.870, is below the fallback of 2.203. For ferro-chromium the Kazakhstan values, 2.350 and 2.870, are the same as the fallback values.

A deduction for carbon prices paid at home will do little to close the gap. The Commission's guidance for non-EU operators counts free allocation under a domestic trading system as a rebate, and all allowances in Kazakhstan's system have been allocated free since 2021, with an average secondary-market price of KZT 455.48, or $0.87, in 2025, according to ICAP. That leaves verified installation data as the main lever. By 2028, when the mark-up rises to 30 per cent and the free allocation factor falls to 90 per cent, the rebar figure on the same default would rise to 5.51 certificates a tonne, on our calculation.