CBAM: New products, new obligations
What the EU's expanded scope means for your business
On 15 September 2026, the European Parliament adopted its negotiating position on the extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products – a development that could have direct implications for businesses importing finished and semi-finished goods into the EU.
From raw materials to finished goods
CBAM entered fully into force on 1 January 2026, covering products across six sectors: aluminium, cement, electricity, fertilisers, iron and steel, and hydrogen. Following a mandatory review, the Commission published a proposal in December 2025 to expand CBAM to downstream products from 2028, focusing primarily on steel- and aluminium-intensive products.
For the proposal to become law, both the European Parliament and the Council must agree. Both institutions broadly support the expansion, and the vote of 15 September 2026 formally confirms Parliament's position ahead of the upcoming Trilogue. Businesses importing finished and semi-finished goods made from the current CBAM materials should expect a broader set of obligations from 2028 onwards.
Which products are expected to be in scope?
While the final list will be determined in the Trilogue, the expansion targets downstream goods manufactured from materials already covered by CBAM. Products currently on the table include:
- Construction materials and prefabricated building products
- Fasteners, fixings, screws, bolts, springs, and wire products
- Machinery parts, industrial robots, and components
- Vehicle parts and electrical components
- Household appliances such as washing machines, dryers, and refrigerators
- Metal furniture
Products appearing in both the Council and Parliament positions are arguably more likely to make it into the final list.
Who will be affected?
The expansion will bring a significantly larger number of businesses into scope — including an estimated 3,800–3,900 SMEs currently with no CBAM obligations. For smaller importers, compliance may be proportionally more burdensome, as they typically have less leverage over suppliers and fewer internal resources for carbon accounting.
Our recommendation
Trilogue negotiations between the Commission, Council, and Parliament are set to begin in October 2026. The three institutions will need to reconcile their respective positions before a political agreement can be reached – expected in Q4 2026. Formal adoption and publication of the final legislation is anticipated in Q1 2027, ahead of a proposed entry into force on 1 January 2028.
The final product list is not yet confirmed, but businesses are well advised to start preparing. Key steps include:
- Mapping proposed product codes against your supply and value chains
- Assessing whether additional products could elevate imports above relevant thresholds
- Estimating financial exposure under the extended product scope
- Exploring decarbonisation strategies to reduce associated costs
Contact our CBAM Team
Please do not hesitate to reach out if you would like to discuss what the extension could mean for your business – including a detailed walkthrough of the specific product codes currently proposed for inclusion in the extended CBAM scope.
