Export Pattern Analysis of South Korea’s Steel Sector Uunder the EU CBAM: Trade Diversion, Carbon Leakage Risks, and Challenges to Environmental Legitimacy

Purpose – This study examines the impact of the EU CBAM on South Korean steel exports. It assesses whether the CBAM induces trade diversion and carbon leakage. Additionally, it evaluates the CBAM’s consistency with WTO environmental exception standards under GATT Article XX. Design/Methodology – The study combines empirical data analysis with supply chain carbon footprint comparisons. Furthermore, it conducts a legal analysis of WTO case law, focusing on necessity, legitimacy, procedural fairness, and non-discrimination. Trade flow changes before and after the CBAM are evaluated quantitatively. Findings – The CBAM has induced explicit trade diversion from major EU countries to major non-EU countries, especially for carbon-intensive hot-rolled steel. This diversion implies increase in global carbon emissions. This study identifies that its effectiveness in fostering technological innovation and reducing emissions remains limited, at least for Korean steel exports. At the same time, the CBAM raises significant concerns under WTO law, particularly regarding necessity and non-discrimination, and faces dispute risks due to procedural flaws. Originality/value – Unlike previous simulation-based analyses, this study utilizes observed trade data from 2018 to 2024 following the introduction of the CBAM in 2021, offering an empirical evaluation of its actual policy effects. The study shows that while the CBAM proclaimed to prevent carbon leakage, it has primarily led to trade diversion, with limited impact on decarbonization among Korean steel exporters. Technological shifts require time and resources; unilateral measures risk triggering retaliatory protectionism. This study contextualizes the CBAM development so far and calls for cooperative approaches to climate governance.