The EU is considering a substantial extension of CBAM further down steel and aluminium value chains. As of 14 September 2026, the legislative process is still open and the Parliament vote is scheduled for 15 September 2026.
Regulatory content last reviewed14 September 2026
CBAM currently applies to selected goods in six sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The current legally applicable scope remains governed by Regulation (EU) 2023/956 as amended. The downstream extension discussed on this page is a legislative proposal, not yet final law.
The policy concern is that carbon leakage can shift further down the value chain. A non-EU manufacturer may import or use steel or aluminium outside the EU, carry out relatively limited transformation, and sell the resulting machinery, fabricated product or equipment into the EU while competing with EU manufacturers bearing EU ETS carbon costs. The extension proposal is designed to reduce that risk and strengthen anti-circumvention rules.
The Commission proposal of 17 December 2025 would add 180 downstream products with a high carbon-leakage risk and a high share of steel or aluminium content. It also contains anti-circumvention measures, additional reporting in specified cases, changes to electricity-emissions rules and an urgency mechanism.
On 12 June 2026 the Council agreed its general approach. According to the European Parliament Research Service, the Council position expands the Commission list to 200 additional metal-intensive industrial, construction and electrical equipment goods and would require annual review of further downstream products from 2028. This is the Council negotiating position, not final law.
ENVI adopted its report on 9 July 2026. The committee report would expand the scope to 457 products and add further anti-circumvention and enforcement provisions. Parliament is scheduled to vote in plenary on 15 September 2026. As of 14 September 2026, that plenary vote has not occurred, so the ENVI report is not yet Parliament’s final negotiating position.
The Commission proposal envisages downstream inclusion from 2028. The final product list can still change through the ordinary legislative procedure. Companies should therefore distinguish current CBAM scope from proposed future scope and avoid treating any Commission, Council or committee list as final until the legislation is adopted and published.
Official proposal and negotiating texts focus on steel- and aluminium-intensive downstream goods. Depending on the final list, categories can include machinery, fabricated metal products, industrial and construction equipment, electrical equipment, vehicle-related components and domestic equipment. The exact CN codes are what ultimately determine legal coverage.
For a downstream product, the document trail can become more complex: finished good → steel or aluminium inputs → upstream CBAM goods → producer → installation → embedded emissions → supporting records. One finished product may contain several CBAM-relevant inputs from several suppliers and installations. The file therefore needs to preserve both product composition and the source history of each relevant input.
Identify which imported finished goods contain significant iron, steel or aluminium inputs. Keep supplier and product-composition information, identify where upstream installation and emissions records would need to come from, follow the legislative process, and avoid redesigning compliance systems around a product list that is not yet final.
The legal information on this page is drawn from official regulatory sources. Weetra explains what those rules mean for the documents and records a business may need; this is not legal advice.
