CBAM extension to downstream products from 2028
Today CBAM covers basic materials. Importers of finished products made of steel or aluminium pay nothing, which creates an incentive to move processing outside the EU. On 17 December 2025 the Commission proposed extending CBAM to downstream goods from 1 January 2028, together with stronger anti-circumvention rules.
What the Commission proposed
- About 180 downstream products with high steel and/or aluminium content (on average 79 % by weight) and high carbon leakage risk, for example machinery parts, tools, fittings, household and industrial articles made of steel or aluminium.
- Embedded emissions would be calculated from the steel and aluminium content of the product, not from the manufacturing of the finished good itself.
- Pre-consumer steel and aluminium scrap would be treated as a precursor, closing a loophole for scrap-based imports.
- A definition of abusive practices and powers for the Commission and national authorities to request additional evidence, aimed at minimal processing, transhipment and misdeclaration of origin.
- A temporary exemption mechanism for specific cases (Article 27a), and a review of the default values for affected goods.
Where the negotiations stand
| Institution | Position |
|---|---|
| Commission | Proposal of 17 December 2025: about 180 downstream products from 1 January 2028. |
| Council | General approach based on the Commission text, with a refined anti-circumvention framework and around 200 products. |
| European Parliament | The Environment Committee voted to extend the list to 457 downstream products. |
| Trilogue | Negotiations between the institutions began in October 2026. The final product list and start date are not yet fixed. |
Who will be affected
The extension would bring in many importers that have never dealt with CBAM: machinery and equipment distributors, construction product wholesalers, metalworking companies sourcing parts abroad. Many of them import far more than 50 tonnes a year once the finished products count, so the number of authorised declarants could rise several-fold.
What to do now
- Map your imports by CN code and flag products in chapters 73, 76, 82–84 and others made mainly of steel or aluminium.
- Ask suppliers for the steel and aluminium content and origin of their inputs; it will be needed to calculate embedded emissions.
- Check whether you already exceed or will exceed the 50-tonne threshold with the new products.
- Follow the trilogue; we track the outcome on the regulatory updates page.