EC proposes CBAM expansion to 180 downstream products
12/06/26
The Carbon Border Adjustment Mechanism (CBAM) currently applies to specific products imported into the European Union, including iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity. From 2028, its scope is expected to be extended to a selection of downstream products, primarily manufactured goods with a high steel or aluminum content. The European Commission has published a proposal for this extension. With this proposal, the scope will be extended as of 1 January 2028 with 180 steel- and aluminum-intensive downstream products.
What does this mean for my business?
Once the proposal is formally adopted, you should review your company’s product portfolio and assess whether you import goods that fall within the proposed expansion of the CBAM scope. If any of your products are affected, it is important to start preparing for the upcoming requirements such as the purchase of CBAM certificates. In addition, if you are not yet registered as a CBAM importer but due to the extension expect to import more than 50 tonnes of CBAM goods from 2028 onwards, you should ensure that you apply in time to become a CBAM declarant. This will help you avoid delays and ensure compliance once the expanded scope comes into effect.
Current scope and scope extension
Since the beginning of 2026, CBAM operates in its definitive phase. It requires importers of raw materials and (semi-) finished goods in scope of CBAM to report embedded greenhouse gas emissions and surrender CBAM certificates. The primary sectors currently covered include iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity.
To prevent carbon leakage and anti-circumvention along the value chain, the European Commission proposes expanding the scope to cover manufactured goods that contain a high share of steel or aluminum. Under the proposed extension, 180 downstream products are to be added to the CBAM scope on 1 January 2028. These goods are typically at a high risk for carbon leakage that are further down the value chain, averaging around 79% steel or aluminum content.
Covered items will include fabricated metals, machinery and industrial equipment, vehicles and vehicle components (such as gearboxes and engines), domestic appliances (such as washing machines and refrigerators), and metal construction equipment. Importers of these upcoming downstream goods will be subject to CBAM certificate requirements once the extension is enacted.
Next steps
The Proposal to amend the CBAM regulation follows the ordinary legislative procedure, which means that the Proposal needs to be adopted by both the Council of the EU and the European Parliament. The proposal has been sent to both to each examine the proposal and propose amendments. The Council agreed its position on 12 June 2026. As soon as the Parliament adopts its position, they then negotiate to reach agreement, after which the proposal can be formally adopted.
As said before, after the Proposal is adopted, the scope extension takes effect as from 1 January 2028.
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