The European Parliament voted on 15 September 2026 and established its negotiating position on the proposed CBAM downstream expansion. The proposal is not final EU law: the ordinary legislative procedure continues, including negotiations with the Council.
Regulatory content last reviewed17 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.
On 15 September 2026, the European Parliament adopted its position in first reading on procedure 2025/0419(COD) and referred the file for interinstitutional negotiations. Parliament’s position is a negotiating position, not final adopted legislation. The Council had already agreed its general approach on 12 June 2026.
Commission proposal, Council general approach and Parliament position are separate stages of the ordinary legislative procedure. The downstream extension becomes binding only if a final legal act is agreed, formally adopted and published. Until then, the currently applicable CBAM product scope remains the legal baseline.
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.
If the proposed extension is ultimately adopted, documentary traceability may need to connect the finished product to relevant steel or aluminium components, the upstream CBAM inputs, producer and installation, embedded emissions and the records supporting those emissions. A finished good can contain several relevant inputs from several suppliers, so preserving product composition and source history becomes more important.
Map imported finished goods that depend materially on iron, steel or aluminium; retain supplier and product-composition records; identify where installation and emissions evidence would have to come from; and follow the negotiations. Do not treat the Commission, Council or Parliament product lists as the final legal scope.
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.
