I. Macroeconomic Environment and Trade Risk Analysis

The steel and metal materials industry is a key sector where both the benefits of FTAs ​​and CBAM (Carbon Difference Assessment) responsiveness
have become increasingly crucial due to the global economic slowdown and strengthened carbon regulations. When the EU CBAM is fully implemented in 2026, carbon certification and LCA reporting for steel and aluminum products will become mandatory.
Korean exporters' FTA competitiveness will be assessed based on tariff reductions and the completeness of their carbon data .

Risk factors

2025-2026 Outlook

Influence (1~5)

Implications

EU CBAM fully implementedDirect taxation of steel and aluminum5Establishing a carbon emissions reporting and LCA system is essential.
IRA (USA)Clean Manufacturing Tax Credit Center4Opportunities to enter the North American low-carbon steel supply chain
China's overproductionPrice and inventory pressures continue4RCEP and Korea-India CEPA can be reused.
Exchange rates and energy costsmild stabilization3Effective investment in energy-saving facilities
The spread of trade restrictionsIncrease in safeguard and AD measures4Parallel use of HS detailed judgment and FTA
Ⅱ. FTA Utilization Rate and Corporate Practice Statistics

While steel and metal materials enjoy significant FTA tariff benefits, their product characteristics (coils, sheets, rolled products, etc.) and complex processing stages make determining their country of origin challenging. While
FTA utilization rates average 78-85% , the burden of carbon data and environmental certification costs is increasing.

division

FTA application rate (%)

Major challenges

Management Points

Hot-rolled and cold-rolled steel sheets (HS7208~7212)84Proof of origin and process refinementEstablishment of a parallel FTA/CBAM reporting system
Stainless steel/alloy steel80Mixing of component materialsBOM-based RVC calculation required
Aluminum sheet (HS7606, etc.)82Environmental certification/LCA requirementsRegeneration rate and power consumption reporting system
small and medium-sized manufacturing and small factories66Data and document staff shortageExpansion of the cooperative FTA support system
III. Matrix of Comparison of Tariffs and Non-Tariffs by Country

While tariff reductions through FTAs ​​remain significant, steel faces rapidly expanding non-tariff risks, including safeguards, anti-dumping, and countervailing duties (CBAM) . While tariff-free benefits remain largely intact within FTA agreements, the gap in actual profitability is widening due to carbon and recycling regulations .

market

MFN(%)

FTA application (%)

difference

Major non-tariff barriers

note

USA2.5~250~2.5-2.5~-22.5Safeguard/IRA Clean Steel RequirementsNorth American Carbon Reduction Supply Chain Linkage
EU3~150-3~-15CBAM Direct Application·EcodesignTaxation begins in earnest in 2026
china5~100~5-5~-10Import quotas and industrial protectionRCEP focuses on internal trade
India and ASEAN10~250~10-10~-25Certification and administrative delaysCumulative use of RCEP and CEPA
Ⅳ. ESG·CBAM Impact

The steel and metal materials industries will be subject to direct EU CBAM taxation starting in 2026, mandating reporting
of product-level carbon emissions (LCA) , electricity mix data , recycling rates , and raw material traceability
. RE100 and green procurement systems will be implemented in parallel, and carbon price competitiveness will determine actual profitability.

policy

applied area

Implementation period

Influence (1~5)

Response strategy

EU CBAMDirect taxation of steel and aluminum20265Building an LCA and emissions data platform
IRANorth American Clean Manufacturing Tax Credit20254Securing a low-carbon raw material supply chain
RE100Power-based manufacturing plantsAlways3Power conversion for steel mills and rolling mills
ESG disclosureLinkage with forward-looking industries2025~20274Preparing for mandatory sustainability management reporting
V. Investment and Supply Chain Transition Scenario

Korea: Maintaining a production hub focused on high-grade steel, eco-friendly steel materials, and high-purity aluminum.

EU: Considering Establishing Local Processing and Packaging Plants to Address CBAM

North America: Expanding the IRA Tax Credit Supply Chain (US-Mexico Joint Venture)

ASEAN: Relocation of low- and mid-priced materials and assembly lines based on RCEP

Ⅵ. AI-based 3-month export and import forecasts

AutoLoop results show that the steel and metal materials industry is showing export growth, centered on eco-friendly steel and lightweight alloys, despite slowing global demand .
The sentiment index (α) of news related to CBAM and expectations for IRA subsidies (β) are positively driving ΔSignal.

variable

Δ(%)

analysis

ΔExport_now+2.5EU and North American exports continue to expand
ΔImport_now+1.7Expanding imports of raw materials and components
ΔPrice_now+0.4Rising prices of high-grade steel and aluminum
ΔSignal_now+0.031Positive signals based on policy and expectations
ΔFTAEffect+0.34Effect of parallel response to tariffs and CBAM
Forecast_3M+0.52 (bullish forecast)Expected stable upward trend within 3 months
VII. Policy Recommendations and System Improvement Roadmap

field

Suggestion

Executor

Expected effect

CBAM responseBuilding an Integrated LCA Platform for Steel and Non-Ferrous MetalsMinistry of Environment and Ministry of Trade, Industry and EnergyEnsuring carbon reliability
FTA+ESG linkageIntroduction of an ESG-based country of origin certification systemKorea Customs Service and Ministry of Trade, Industry and EnergyEnsuring data consistency
carbon tax offsetReview of export tax credits to address CBAMMinistry of Strategy and Finance and Ministry of Trade, Industry and EnergyCost savings
Green FinanceRE100-based financial incentivesPolicy Finance and Industrial BankInvestment Promotion
technological innovationDevelopment of hydrogen reduction ironmaking and low-carbon aluminum technologiesGovernment/privateMaintaining global competitiveness
Ⅷ. Summary of Conclusions

FTA competitiveness = moving to a dual axis of tariffs + carbon data.

With the implementation of the EU CBAM, the carbon reliability of steel and aluminum will determine the effectiveness of FTA utilization.

Forecast_3M: +0.52 → Strong demand for eco-friendly steel, with a gradual upward trend centered on North America and the EU.

Future strategic directions:
① CBAM-LCA data standardization
② IRA-based participation in the North American supply chain
③ Expanding the accumulation of RCEP raw materials
④ Establishing an ESG+FTA composite certification system.