The scope of CBAM may be extended to additional product groups, including more processed goods containing significant amounts of steel or aluminium.
CBAM may be extended to downstream products
On 6 July 2026, the European Parliament’s Committee on the Environment, Climate and Food Safety adopted its position on the extension and strengthening of the CBAM mechanism.
The proposed changes provide for the inclusion of selected downstream products, meaning more processed goods containing significant amounts of steel or aluminium. The proposed list includes, among others, fasteners, wires, springs and household articles.
The extension is intended to reduce the risk of CBAM circumvention
The changes are intended to reduce the risk of CBAM being circumvented through the import into the European Union of finished products instead of basic materials already covered by the mechanism.
The proposal also strengthens provisions allowing action to be taken where goods are modified or processed in order to avoid CBAM obligations.
The new rules may apply from 2028
The position adopted by the ENVI Committee is aligned with the general direction taken by the Council of the EU. However, the legislative process is still ongoing, and the final scope of the new obligations will depend on the outcome of negotiations at EU level.
It has been proposed that the extension should apply from 1 January 2028.
Importers should review their supply chains in advance
For importers, the proposed changes mean that CN codes, supply chain structures and the ability to obtain embedded emissions data from non-EU suppliers should be reviewed in advance.
It will also be important to continue monitoring the legislative process and further published updates. The scope of products covered by CBAM, detailed reporting requirements and the implementation timetable may still change before the final legislation is adopted.
Please contact us if your organisation requires support in assessing whether the planned extension of CBAM may affect the goods it imports.
We support businesses in analysing CN codes, import structures and the potential impact of CBAM changes on individual product groups. We also help establish processes for obtaining emissions data from non-EU suppliers and monitor legislative developments relevant to importers.
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