EU CBAM downstream products: what the proposed extension covers, for whom and from when

If it becomes law, the Carbon Border Adjustment Mechanism (CBAM) would cover about 180 more steel and aluminium goods, by the count of the European Parliamentary Research Service (EPRS), from springs, nails and washing machines to cranes, cables and goods vehicles 211. Nothing changes yet: the extension is in a Commission proposal on which the Council and Parliament have not reached an agreement, and as proposed it would apply from 1 January 2028 14. What CBAM requires today is on our CBAM hub.

What would the proposal add to CBAM?

The Commission proposal COM(2025) 989 of 17 December 2025 would extend CBAM to "selected steel and aluminium-intensive downstream products": goods made further down the value chain from the steel and aluminium CBAM already covers 1. Today CBAM covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, mostly as basic materials and some articles 17. The Commission says the extension targets the downstream goods most at risk of carbon leakage, the move of production to countries with laxer climate rules, and that contain a large share of CBAM goods 1.

The proposal would do this in three ways:

• It would replace the iron and steel table in Annex I of the CBAM Regulation and add a new table, "Combined metal products" 2.
• It would count the emissions of pre-consumer steel and aluminium scrap, the offcuts left over from making metal goods, as an input (a "precursor") of CBAM goods; post-consumer scrap would stay out 12.
• It would let the Commission name downstream goods whose default emission values carry no mark-up, because their supply chains are complex 1. In the Council's text, default values would be set at the exporting country's average emission intensity, "increased by a proportionately designed mark-up" 3.

For the iron and steel, aluminium and combined metal goods, embedded emissions would be worked out from the emissions in the steel and aluminium they contain 12. Our explainer on default values and actual emissions covers how that works for today's goods.

Is my product on the proposed list?

Check your product's Combined Nomenclature (CN) code, the EU's eight-digit customs product code, against the proposal's annex 2. EPRS counts 180 downstream products in the Commission's list, with on average 79% steel or aluminium content 11. The table groups the codes the proposal adds, by type of product. "ex" before a code means only part of it is covered, in most cases goods "containing steel or aluminium" 2.

Source: Annexes to Commission proposal COM(2025) 989, 17 December 2025. Codes listed under today's iron and steel table are left out.

Several vehicle codes leave out named subheadings, such as 8704 21 39 and 8704 21 99, so check the exact wording in the annexes to the proposal 2. For most combined metal products, the proposal counts perfluorocarbons as well as carbon dioxide 2.

The list may still grow. The Council's position adds a further 200 codes, such as boilers, turbines, heat pumps, trailers and car parts, and drops the three medical codes 9018 32 10, ex 9018 90 75 and ex 9018 90 84 311. Parliament's text goes further, with whole headings such as chapter 73, "Articles of iron or steel", and 8413 pumps, 8418 refrigerators and freezers, 8704 goods vehicles and 8716 trailers 8. EPRS counted 457 products in the committee report behind Parliament's position 11. If your code is on any of the three lists, it could end up in the final text.

From when would it apply, and to whom?

As proposed, the new goods would come under CBAM from 1 January 2028 1. The Council's position keeps that date 3. Parliament's amendments don't change the proposal's application article, so on our reading its text keeps 1 January 2028 as well 18. The date is pending until the amending regulation is adopted and published in the Official Journal; the regulation would enter into force on the third day after publication 1.

The CBAM Regulation applies to the goods listed in its Annex I, so once the new goods are listed, their importers would have the same obligations as importers of today's CBAM goods, unless the 50-tonne exemption covers them 569. Today, an importer is exempt for a calendar year if the net mass of its CBAM goods, all CN codes added together, stays at or under 50 tonnes 56. Our reading: once downstream goods are in Annex I, they would count towards the same 50 tonnes as your other CBAM goods 56. Our explainer on the threshold walks through the test.

The Commission expects the threshold to keep most new importers out. It estimates that more than 90% of importers in the sectors covered by the extension would have no CBAM obligations, while over 99% of emissions stay in scope 1. It also estimates that about 3,800 to 3,900 more small and medium-sized enterprises (SMEs) would face CBAM obligations 1. These are Commission estimates in the proposal's explanatory memorandum, not counts.

Above the threshold, importers are only entitled to import CBAM goods once they have been granted an authorisation as authorised CBAM declarant, or if they appoint a representative authorised as CBAM declarant, and that would apply to the new goods too 1. Our explainer on authorised declarants covers the application. Producers of the new goods outside the EU could register in the CBAM registry so their verified emissions can be used, as our guide for non-EU producers explains 1.

What do the Council and Parliament want to change?

Both want more products than the Commission, and they differ on scrap, the threshold and emergency removals. None of these positions is law, and no agreement has been reached 4.

Sources: COM(2025) 989 and its annexes; Council general approach ST 10423/26; Parliament's amendments P10_TA(2026)0276; EPRS At a glance, September 2026. The EPRS counts are its own; the Council and Parliament texts give lists, not totals.

The Council also wants the Commission to report at least once a year from 1 January 2028 on further downstream products it recommends adding 3. For a business, that means the list could keep growing after 2028.

What else would the proposal change?

The same proposal tightens the rules against getting round CBAM and changes how imported electricity is counted 1. Each change is a proposal, not law:

• Proof of origin. Declarants could have to show that goods declared with actual emissions were made at the declared installation and time, and the Commission could set extra evidence rules for goods and origins at high risk of "abusive practices" 1. Adjusting supply chains artificially to get lower default values would count as circumvention 1. Our explainer on default values carries these as pending.
• Producer registration. Actual emissions would have to be provided by a producer registered in the CBAM registry; the new registration rule would apply from 1 January 2028 1. Our guide for non-EU producers has the detail.
• Guarantees and representatives. Authorities could ask for a guarantee in more cases, and indirect customs representatives would give the Economic Operators Registration and Identification (EORI) number, or another national identification number, of each importer they act for 1. See our explainer on authorised declarants.
• Electricity. Default values for imported electricity would reflect electricity from all sources, not only fossil fuels, and the conditions for declaring actual emissions would be eased 12. As proposed, the new electricity definitions and conditions would apply to electricity imported from 1 January 2026, so that they count for the first declarations due by 30 September 2027 1.

Where does it stand, and what happens next?

Parliament and the Council have not reached an agreement on the proposal, and nothing has been adopted 4. The Council agreed its position on 12 June 2026 3. On 15 September 2026, Parliament adopted its amendments and referred the file back to its committee for interinstitutional negotiations, the talks with the Council 4. On 21 October 2026, Parliament's procedure file listed no later step and still gave the stage as "Awaiting Parliament's position in 1st reading" 4.

In June 2026, the Council said it aimed for an agreement "before the end of the year" 10. Any agreement still has to be adopted by both and published in the Official Journal before it becomes law 1. We will update this page when that happens; the CBAM hub shows the current status.

What can I do now?

You have no new obligation until the amending regulation is adopted 1. You can prepare in four steps:

1. Check the CN codes you import against the Commission's annex, and against the Council and Parliament lists, since the final list may be longer 238.
2. If any code is on a list, add up your yearly net mass of CBAM goods, old and new, to see if you would cross 50 tonnes 56. Our threshold explainer shows how.
3. If you would cross it, you can ask your suppliers which steel and aluminium their products contain and where it was made, since embedded emissions would be worked out from those inputs 2.
4. Watch for the final text: the start date, the list and the scrap rules can all still change 4.

This is general information, not legal advice. For decisions about your company, check with a lawyer or adviser.

What is still open?

The final product list, the treatment of steel scrap and any aluminium-specific threshold depend on the talks between Parliament and the Council 38. Whether 1 January 2028 holds depends on when the text is adopted: the Commission and Council texts name that date, and Parliament's amendments leave it untouched 138.