The CBAM downstream expansion would extend the Carbon Border Adjustment Mechanism to finished steel and aluminium goods, such as fasteners, springs, and household appliances, from January 1, 2028, and the three EU legislative institutions currently back three different product lists ranging from roughly 180 to 457 items. The European Commission proposed approximately 180 downstream products in COM(2025)989 on December 17, 2025. The Council of the European Union widened that list to roughly 200 products in its general approach adopted on June 12, 2026. The European Parliament's ENVI committee went further, backing a position covering an estimated 457 products on July 6, 2026, by a vote of 56 in favor, 11 against, and 12 abstentions. None of the three positions is final law as of July 11, 2026: the full Parliament has not yet voted, and trilogue negotiations between the Commission, Council, and Parliament have not begun.
This tracker compares what each institution has proposed, which product categories would be added, how the three positions treat anti-circumvention and scrap, what happens next on the legislative calendar, and how EUROFER, European Aluminium, and German importers have reacted.
What Is the CBAM Downstream Expansion?
The CBAM downstream expansion is a proposed amendment to Regulation (EU) 2023/956 that would widen CBAM's scope beyond its six current sectors to cover finished goods manufactured from steel and aluminium precursors. Today, CBAM applies only to iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen in largely primary or semi-finished form. A steel importer who brings in hot-rolled coil faces CBAM obligations; a manufacturer who imports finished steel fasteners made from that same coil currently does not, because the finished product sits outside CBAM's product list in Annex I.
The expansion proposal, formally procedure 2025/0419(COD), aims to close that gap. The Commission's own reasoning, published alongside COM(2025)989, is that downstream products let non-EU producers sidestep CBAM's carbon cost simply by shipping one processing step further down the value chain, undermining the carbon leakage protection the regulation was designed to provide. The CBAM Regulation (EU) 2023/956 legal reference guide covers how this proposal fits into the regulation's broader legislative history, including the 2025 Omnibus amendments.
CBAM Downstream Expansion Timeline: From Proposal to 2028
The table below lists every confirmed milestone in the downstream expansion procedure from the Commission's original proposal through the target 2028 start date, with each milestone's legal status noted explicitly.
| Date | Milestone | Institution | Status as of July 11, 2026 |
|---|---|---|---|
| December 17, 2025 | Commission publishes COM(2025)989, proposing roughly 180 downstream products | European Commission | Published; opens the ordinary legislative procedure |
| April 10, 2026 | ENVI rapporteur Mohammed Chahim tables draft report (PE786.835) | European Parliament (ENVI) | Draft only; superseded by the July 6 committee vote |
| June 12, 2026 | Council adopts general approach, roughly 200 products | Council of the EU (ECOFIN) | Political agreement; not final law |
| July 6, 2026 | ENVI committee adopts position, 56 for, 11 against, 12 abstentions, roughly 457 products | European Parliament (ENVI) | Committee position; awaiting full plenary vote |
| September 14, 2026 | Indicative plenary vote to adopt Parliament's first-reading negotiating mandate | European Parliament (plenary) | Scheduled; not yet held |
| Late 2026 (target) | Trilogue negotiations between Commission, Council, and Parliament | All three institutions | Not yet started |
| January 1, 2028 | Proposed downstream expansion enters into force | N/A | Target date; contingent on trilogue outcome |
The current OEIL procedure status reads "Awaiting Parliament's position in 1st reading," which confirms that even the Parliament side is not yet settled: the ENVI vote is a committee-level position, not the position of the full Parliament. For every other date and deadline already locked into the definitive CBAM regime, from certificate sales to declaration deadlines, see the full CBAM timeline.
Commission, Council, and Parliament Positions Compared
The three institutions agree that CBAM should expand to downstream steel and aluminium goods starting in 2028, but disagree sharply on how large that expansion should be. Each successive position has widened the product list and tightened the anti-circumvention rules relative to the one before it.
European Commission Proposal: COM(2025)989
The Commission's original proposal, tabled December 17, 2025, covers approximately 180 additional product codes, extending CBAM's declarant base to importers who currently fall outside the regulation's scope. The added products are predominantly intermediate industrial goods with substantial steel or aluminium content, such as base metal fittings, cylinders, and industrial radiators, alongside a smaller share of household goods.
Council General Approach (June 12, 2026)
The Council, meeting as the Economic and Financial Affairs Council (ECOFIN), adopted its general approach on June 12, 2026, refining and slightly widening the Commission's list to roughly 200 products, a figure reported by EUROFER. Council coverage categories include sheet piling, railway material, gas containers, wire mesh, fencing, nails, furniture fittings, engines, pumps, robots, cranes, vehicle components, certain medical devices, metal furniture, and prefabricated buildings. The Council's position also brings pre-consumer steel and aluminium scrap into CBAM's precursor accounting and gives the Commission a mandate to review and potentially expand the product list annually. A general approach is a Council negotiating position, not adopted legislation; it sets the mandate for trilogue but carries no legal force on its own.
European Parliament ENVI Position (July 6, 2026)
The Environment, Climate and Food Safety Committee adopted its position on July 6, 2026, by 56 votes in favor, 11 against, and 12 abstentions, going well beyond both the Commission and the Council. Trade press puts ENVI's list at approximately 457 products, adding categories the Council list does not cover, including solar panels, kitchen utensils, and components for electric motors, washing machines, and heat pumps, on top of the fasteners, wire, springs, and household articles already flagged in Council and Commission coverage. This is a committee position, not yet the Parliament's official first-reading mandate; that step is scheduled for the September plenary.
The table below lines up the three positions side by side.
| Institution | Adoption date | Approximate product count | Decision type | Legal status |
|---|---|---|---|---|
| European Commission | December 17, 2025 | ~180 | Legislative proposal (COM(2025)989) | Starting point for negotiation |
| Council of the EU | June 12, 2026 | ~200 | General approach (ECOFIN) | Council's negotiating mandate |
| European Parliament (ENVI) | July 6, 2026 | ~457 | Committee vote, 56-11-12 | Awaiting full plenary adoption, September 14, 2026 |
Which Products Would the CBAM Downstream Expansion Add?
The products under discussion fall into two broad groups: industrial intermediate goods and finished consumer or household articles, both built substantially from steel or aluminium. The list below reflects categories named across the Commission, Council, and ENVI positions; the final list depends on the outcome of trilogue negotiations.
- Fasteners and fixings: nails, screws, bolts, springs, and wire products
- Structural and industrial metalwork: sheet piling, railway material, cranes, robots, pumps, and engines
- Vehicle and machinery components: vehicle body parts, compression-ignition engine parts, and farming machinery
- Containers and pressure equipment: gas containers, cylinders, and industrial radiators
- Buildings and furniture: metal furniture, furniture fittings, and prefabricated buildings
- Household and consumer goods: kitchen utensils, household appliances, and (in the ENVI position only) solar panels, materials for electric motors, washing machines, and heat pumps
- Medical devices: select devices with substantial steel or aluminium content
Current CBAM scope already covers the raw and semi-finished forms of these same materials in detail; the CBAM steel CN codes list and the CBAM aluminium CN codes list show exactly what is already in scope under Chapters 72, 73, and 76. The downstream expansion, if adopted, would extend coverage further down those same chapters and into adjacent goods classifications, without changing how emissions are calculated for the sectors already covered under the steel and aluminium sector rules.
Anti-Circumvention Measures: How the Three Positions Compare
All three positions strengthen anti-circumvention rules beyond the version currently in force, but they differ on scrap and enforcement mechanics. The comparison below focuses on the measures with the clearest textual differences.
| Measure | Commission (COM(2025)989) | Council general approach | ENVI position |
|---|---|---|---|
| "Slight modification" circumvention rule | Targets minimal processing to dodge CBAM | Strengthens oversight of high-risk companies | Clarifies that "slightly modifying" goods covers slight processing |
| Default values for suspected circumvention | Not specified in detail | Expands Commission powers to address non-compliance | Empowers Commission to apply default values where circumvention patterns are detected |
| Online sales / split shipments | Not addressed | Not addressed | Reportedly addresses split shipments and online sales circumvention (specific enforcement mechanism not fully detailed in public summaries) |
| Pre-consumer scrap | Proposed as a CBAM precursor | Included as a precursor, without a dedicated impact assessment (EUROFER objection) | Not resolved by the July 6 vote |
| Post-consumer scrap | Excluded | Excluded | Excluded; European Aluminium's central unresolved objection |
| Product list review mechanism | Not specified | Commission mandated to review and potentially expand the list annually | Not specified in available summaries |
The CBAM anti-circumvention rules page explains how the currently enforceable circumvention rules work under the regulation as it stands today; the measures compared above are all proposed additions, none of which are in force yet. The post-consumer scrap gap is the sharpest open dispute: none of the three positions currently brings post-consumer aluminium or steel scrap inside CBAM's precursor accounting, and industry groups on the metals side argue this leaves a structural loophole large enough to undermine the expansion's carbon leakage goal.
What Happens Next: Plenary Vote and Trilogue Timeline
Parliament is scheduled to adopt its first-reading negotiating mandate during the September plenary session, held in Strasbourg from September 14 to 17, 2026. Once that mandate is adopted, trilogue negotiations between the Commission, Council, and Parliament can begin; the three institutions are targeting a final political deal in late 2026 or early 2027, which would still leave time to finalize the legal text before the proposed January 1, 2028 start date.
Three issues look set to dominate the trilogue.
- Size of the product list. Negotiators must reconcile the Commission's roughly 180 products, the Council's roughly 200, and the Parliament's roughly 457, a gap wide enough that the final figure could land anywhere in that range.
- Scrap treatment. Pre-consumer scrap is included as a precursor in the Council position but was flagged by EUROFER as lacking a dedicated impact assessment; post-consumer scrap remains excluded from all three positions despite European Aluminium's objections.
- De minimis interaction. The existing 50-tonne annual mass exemption, explained in the CBAM de minimis threshold guide, was designed around raw and semi-finished materials; industry groups argue it does not scale well to lightweight, high-value finished goods, and trilogue negotiators have not yet indicated whether the threshold will change for downstream products.
Industry Reactions to the CBAM Downstream Expansion
Industry associations across the steel, aluminium, and import trade have responded to each institutional position as it landed, and their reactions cluster around one shared theme: welcome the direction, but flag the expansion as incomplete.
EUROFER: "A Step in the Right Direction, But Not Sufficient"
EUROFER, the European steel industry association, reacted to the Council's June 12 general approach by calling it "a step in the right direction, but it will not be sufficient to prevent carbon leakage," a statement attributed to Director General Axel Eggert. EUROFER welcomed the roughly 200-product extension but said it fails to give structural coverage to the full range of steel-intensive goods, and it regretted the inclusion of pre-consumer steel scrap as a CBAM precursor without a dedicated impact assessment, warning of unintended effects on scrap markets and the circular economy. The association also flagged unresolved resource-shuffling risk, where lower-carbon steel is directed to the EU while higher-carbon output continues to reach other markets.
European Aluminium: "Key Loopholes Unresolved"
European Aluminium responded to the July 6 ENVI vote on July 8, 2026, saying key aluminium loopholes remain unresolved. Its central concern is post-consumer scrap: imported products can claim lower carbon costs by declaring post-consumer scrap content, and the association estimates roughly a quarter of global aluminium production could circumvent CBAM obligations this way. The association also argues the existing 50-tonne de minimis threshold is unsuited to aluminium's value-to-weight ratio, illustrating the point with an example in which aluminium doors for a 200-room hotel renovation weigh only about 9.2 tonnes, well under the exemption threshold despite representing meaningful embedded emissions. European Aluminium's demands include placing post-consumer scrap inside Annex III and moving toward a single default value framework for scrap-containing products.
BGA: Calling for a "Stop the Clock" on the Expansion
BGA, the German Federal Association of Wholesale, Foreign Trade and Services, took the opposite position in an April 30, 2026 statement, calling for a "Stop the Clock" on the downstream expansion altogether. BGA argues that CBAM is becoming an increasingly complex trade instrument with a sharply rising administrative burden, warning this falls hardest on Mittelstand importers dependent on global supply chains. German-language coverage of the expansion, including its implications for German importers of fasteners and wire products, is available on the German section of this site at CBAM-Erweiterung 2028.
How Should Importers Prepare for the CBAM Downstream Expansion Now?
Importers should start preparing before the product list is finalized, because the compliance groundwork, not the legal text, is the slower-moving piece. The steps below apply regardless of which of the three product-count scenarios eventually prevails.
- Map your import catalogue against all three product lists. A product that falls under only the ENVI list still carries meaningful risk given how far negotiations could move.
- Treat September 14, 2026 as the next hard deadline to watch. The plenary vote converts the ENVI committee position into Parliament's actual negotiating mandate.
- Review scrap content in your existing supply chain. Scrap rules remain among the least settled parts of the file, so understand how each position treats pre-consumer and post-consumer content.
- Build supplier data collection habits now. The CBAM compliance checklist and the authorized declarant application process already require supplier engagement for covered sectors; that infrastructure extends naturally to downstream products if they enter scope.
- Watch the trilogue, not just the votes. General approaches and committee positions are negotiating mandates, not law, so the product list and scrap treatment can still change before any final text is adopted.
CBAM's downstream expansion sits inside a broader pattern of jurisdictions building their own carbon border rules; the global CBAM landscape page tracks how other countries are responding in parallel.
Frequently Asked Questions About the CBAM Downstream Expansion
Is the CBAM Downstream Expansion Already Law?
No. As of July 11, 2026, the downstream expansion is an active legislative proposal, procedure 2025/0419(COD), with three institutional positions on the table (Commission, Council, ENVI committee) but no adopted final text. The current CBAM regime, in force since January 1, 2026 under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, does not yet cover downstream products.
How Many Products Will the CBAM Downstream Expansion Cover?
The number is unsettled and ranges from approximately 180 to approximately 457 depending on which institutional position prevails. The Commission proposed roughly 180 products, the Council widened this to roughly 200, and the European Parliament's ENVI committee adopted a position covering an estimated 457 products on July 6, 2026. The final figure depends on the outcome of trilogue negotiations expected to start in late 2026.
When Does the CBAM Downstream Expansion Start?
All three institutional positions target January 1, 2028 as the start date. This date has not changed across the Commission's original proposal, the Council's general approach, or the ENVI committee's position, even though the product list has changed substantially between them.
What Is the Difference Between the Commission, Council, and Parliament Positions?
The three positions differ mainly in scope and enforcement strength. The Commission's COM(2025)989 proposal (~180 products) is the baseline text. The Council's general approach (~200 products, adopted June 12, 2026) adds pre-consumer scrap as a precursor and a mandate for annual list reviews. The ENVI committee's position (~457 products, adopted July 6, 2026) adds more household and consumer categories, plus stronger rules on slight processing and online sales circumvention. None of the three is binding on its own; they converge only through trilogue negotiation.
Will Post-Consumer Scrap Be Covered by the CBAM Downstream Expansion?
Not under any of the three current positions. Pre-consumer scrap appears as a proposed precursor in the Council's general approach, but post-consumer scrap remains excluded from the Commission, Council, and ENVI texts alike. European Aluminium has named this the single largest unresolved loophole in the expansion, arguing that roughly a quarter of global aluminium production could avoid CBAM obligations by declaring post-consumer scrap content.