Commission proposes extending CBAM to 180 downstream products from 2028

What happened

On 17 December 2025 the European Commission presented a package of proposals to strengthen CBAM, the EU's Carbon Border Adjustment Mechanism (COM(2025) 989). The package is the second major change, following the recently enacted simplification regulation.

According to the Commission's announcement, the proposal includes:

• Downstream products: From 1 January 2028, CBAM scope will be extended to 180 steel- and aluminium-intensive downstream products. Of these, 94 percent are industrial supply chain products used in heavy machinery and specialised equipment (with an average steel and aluminium content of 79 percent); 6 percent are household goods.
• Anti-circumvention measures: More detailed reporting and traceability; powers for the Commission to request additional evidence against misdeclared emission intensity and to apply country default values instead of unreliable actual values. Pre-consumer steel and aluminium scrap is also brought into the calculation.
• Temporary Decarbonisation Fund: Refunding part of ETS costs to EU producers of CBAM goods to address the risk of carbon leakage on exports.
• Partner countries: Trade-facilitating measures such as an equivalence concept for the carbon price deduction and mutual recognition of accreditation bodies.

The proposal has not become law. According to the European Parliamentary Research Service, the Council of the EU adopted its general approach on 12 June 2026 and expanded the list; Parliament's ENVI committee adopted its report on 9 July 2026. The final product list will be set in trilogue negotiations.

Who is affected

The proposal shifts CBAM's reach in Türkiye from raw material producers to manufacturers. Turkish companies exporting machinery, equipment, metal components and similar steel- or aluminium-containing products to the EU may have to report the embedded emissions in their products from 2028. That will require collecting installation-level emissions data from their own steel and aluminium suppliers. If the data cannot be provided, the importer will have to fall back on default values.

What companies should do

• Compare your products' customs tariff codes (GTİP in Türkiye, CN in the EU) with the codes in the proposal and in the Council list.
• Start asking your steel and aluminium suppliers now for embedded emissions and installation-of-origin information.
• Set up your product carbon footprint infrastructure to collect data in line with the CBAM method.

Alalëa supports embedded emissions calculations for downstream products and supply chain data collection: CBAM readiness.