Three different downstream product lists exist for the CBAM 2028 expansion as of July 2026, and none of them is final. The European Commission's original proposal, COM(2025)989 of December 17, 2025, covers approximately 180 CN codes. The Council of the EU widened that list to roughly 200 products in its general approach of June 12, 2026. The European Parliament's ENVI committee went further still on July 6, 2026, adopting a position that trade press puts at 457 products. Each list targets the same core idea, steel and aluminium goods manufactured one or more processing steps beyond the raw materials CBAM already covers, but the three lists disagree sharply on how far downstream that coverage should reach.
The gap matters because the product list determines which CN codes an EU importer must track from January 1, 2028, the date all three institutions still target for entry into force. This guide compares what each institution's list actually covers, sets the product categories side by side, and explains why full CN-level certainty will not exist until trilogue negotiations conclude.
What Is the CBAM Downstream Product List?
The CBAM downstream product list is the set of finished and semi-finished steel and aluminium goods that the European Commission, the Council, and the European Parliament each propose adding to CBAM's Annex I scope from January 1, 2028. These goods sit one or more manufacturing steps beyond the six sectors CBAM already covers in its definitive phase: iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen. A steel tube, a bag of screws, and a washing machine cabinet are examples of downstream products; the hot-rolled coil or aluminium ingot used to make them already sits inside CBAM's existing scope.
The legal vehicle for the expansion is COM(2025)989, a proposal to amend Regulation (EU) 2023/956 that the Commission published alongside a companion proposal for a Temporary Decarbonisation Fund. Neither proposal is adopted law. Both move through the EU's ordinary legislative procedure, which requires the Council and the Parliament to agree a common text with the Commission before either becomes binding. The CBAM Omnibus simplification package, Regulation (EU) 2025/2083, is a separate, already-adopted measure that changed procedural rules such as the de minimis threshold. It does not touch product scope and is unaffected by this expansion.
The Three Institutional Positions Compared
The table below sets out where each institution stands as of July 2026, including the product count each position uses and its current procedural status.
| Institution | Position | Date adopted | Downstream products | Status |
|---|---|---|---|---|
| European Commission | Proposal COM(2025)989 | December 17, 2025 | Approximately 180 | Starting point for negotiations |
| Council of the EU | General approach | June 12, 2026 | Approximately 200 | Council's negotiating mandate |
| European Parliament, ENVI committee | Committee position, vote 56-11-12 | July 6, 2026 | Approximately 457 (trade press estimate) | Awaiting Parliament plenary confirmation |
None of these three figures is a finished, adopted CN code list. The Commission's number comes from its own proposal text and impact assessment. The approximately 200 figure for the Council is the steel trade association Eurofer's characterization of the Council's general approach, which the Council has not itself published as a single round number, and the Parliament's approximately 457 figure likewise comes from trade press coverage rather than an official count. Treat all three figures as directional, not exact, until trilogue fixes a single list.
Which Product Categories Are on the CBAM Downstream List?
Steel and aluminium products fall into five broad category groups across the three institutional positions, ranging from structural steel to household appliances. Each institution's public materials name overlapping but not identical examples within these groups.
- Structural steel and construction products, including sheet piling, railway materials, gas containers, and structures and parts of structures of iron or steel
- Tubes, pipes, and hollow sections made of steel or aluminium
- Fasteners, such as screws, bolts, nuts, and nails
- Wire products, including wire mesh, fencing, and springs
- Household articles and appliances, including washing machines and other white goods, kitchen utensils, and heat pumps
Structural Steel: Sheet Piling, Rails, Tubes, and Gas Containers
Sheet piling, railway materials, and gas containers appear explicitly in the Council's general approach as core structural steel categories, alongside tubes, pipes, and hollow sections that the Commission's original proposal already lists. These products sit closest to the existing CBAM steel sector, because they are typically produced directly from hot-rolled coil, plate, or bar stock that already carries a CBAM obligation as a raw material. The CBAM steel CN codes guide sets out the current Chapter 72 and 73 coverage these downstream categories would extend.
Fasteners, Springs, and Wire Products
Fasteners and wire products form the second major category across all three positions. The Commission's proposal names screws, bolts, and composite metal products. The Council's general approach adds wire mesh, fencing, and nails explicitly. The ENVI committee's position, per its own press materials, covers "fasteners, wire, springs and household articles" as a named group. Springs appear as an explicitly named category only in the Parliament's position among the sources reviewed for this guide, though the broader wire products heading in the Commission and Council lists may already capture some spring types depending on the final CN code mapping.
Household Articles, Appliances, and White Goods
Household articles and appliances form a category every institution addresses, though with different named examples. The Commission's proposal cites domestic appliances generally. The Council's general approach names agricultural and household appliances alongside engines, pumps, refrigeration equipment, industrial robots, cranes, lifts, electric motors, and transformers. Trade press coverage of the ENVI committee vote cites solar panels, kitchen utensils, materials for electric motors, washing machines, and heat pumps as specific items inside the Parliament's much larger list.
Machinery, Vehicle Components, and Other Fabricated Goods
Vehicle components, machinery, and other fabricated metal goods round out the fourth category. The Commission's proposal names vehicle components and construction equipment. The Council's general approach adds prefabricated buildings, metal furniture, and certain medical devices. Furniture fittings appear explicitly in both the Commission and Council lists. The common feature across this category is that steel or aluminium is a major but not exclusive input, which raises the calculation questions covered in the next section.
How Does the Product Count Differ From the Category List?
A larger product count does not necessarily mean broader category coverage; it more often means finer subdivision within the same categories. The Council's move from roughly 180 to roughly 200 products largely reflects added specificity within categories the Commission already proposed, plus a handful of additions, such as industrial robots and prefabricated buildings, named in Council materials but not in the Commission's original list. The Parliament's jump to roughly 457 is a larger structural change: ENVI's position brings in a wider set of finished consumer and industrial goods, described in its own materials as "a long list of downstream products," while also tightening the anti-circumvention rules that apply to all of them.
Two anti-circumvention changes in the ENVI position affect how the eventual product list will function in practice, regardless of its final size. First, the ENVI text clarifies that slightly modifying a covered good still counts as processing subject to CBAM, closing a loophole where minimal transformation abroad could shift a product just outside the covered CN codes. Second, it gives the Commission authority to apply default values where it detects a circumvention pattern, rather than requiring case-by-case proof for each shipment. Both changes sit alongside the existing CBAM anti-circumvention rules under Article 27 of Regulation (EU) 2023/956, which already prohibit shipment splitting, origin rerouting, and minor processing for the six sectors in force today.
How Would Downstream Product Emissions Be Calculated?
Only emissions embedded in the precursor materials used to make a downstream product would count toward its CBAM obligation, not the emissions from processing or assembling that product. The Commission's proposal introduces this precursor-only principle through a new Annex VIII, which lists the precursor materials, such as hot-rolled steel coil or primary aluminium, that feed into each downstream product category. A steel door manufactured outside the EU, for example, would carry a CBAM obligation tied to the embedded emissions of the steel sheet used to make it, not to the energy used in cutting, forming, or coating that sheet.
This general principle is proposed, but the detailed calculation methodology is not yet settled. Products that combine precursors from multiple countries and multiple production stages raise a technical question none of the three institutional positions has fully answered: how to allocate embedded emissions when a single finished good, a machine part, for example, contains steel from one country, aluminium from another, and assembly in a third. Default values for complex multi-component goods are expected to fill part of this gap, similar to the role CBAM default values already play for the six current sectors, but the specific default-value methodology for downstream goods has not been published.
What Happens Next in the Legislative Process?
The European Parliament's full plenary is scheduled to confirm its first-reading negotiating mandate during the September 14 to 17, 2026 sitting in Strasbourg, after which trilogue negotiations between the Commission, Council, and Parliament begin. The three institutions are targeting a political agreement in late 2026 or early 2027, which would leave time for the technical work needed to support entry into force on January 1, 2028: CN code finalization, default value calculation, and IT system updates. As of July 2026, the legislative procedure file for COM(2025)989 lists the status as awaiting Parliament's position in first reading, confirming that formal trilogue negotiations have not yet begun.
Key Open Issues Trilogue Negotiators Must Resolve
Four questions remain open heading into trilogue, and each one affects which CN codes ultimately appear on the final list.
- Final product count and category boundaries. Negotiators must reconcile the Commission's 180, the Council's approximately 200, and the Parliament's approximately 457 into a single list, a gap too large to close through minor drafting adjustments alone.
- Whether the 50-tonne de minimis threshold applies per product or cumulatively. The existing exemption under the six current sectors applies per importer per year across all covered goods; whether downstream products join that same aggregate or receive a separate threshold is unresolved.
- Multi-country precursor emissions methodology. No institution has published a finished methodology for goods that combine precursors and processing across several jurisdictions.
- Treatment of pre-consumer versus post-consumer scrap. The Commission's proposal brings pre-consumer steel scrap into CBAM as a precursor from 2028 but leaves post-consumer scrap out, a gap both Eurofer and European Aluminium flagged as unresolved even after the ENVI vote.
Sectors already inside CBAM's definitive phase are not affected by any of this. Existing obligations for steel and aluminium importers, including authorization, quarterly certificate holding, and the September 30, 2027 first declaration deadline, run on their own timeline and do not depend on how the downstream expansion resolves.
Frequently Asked Questions About the CBAM Downstream Product List
Is the CBAM Downstream Product List Final?
No. As of July 2026, none of the three institutional lists is final. The Commission's approximately 180 products, the Council's approximately 200, and the Parliament's approximately 457 remain negotiating positions, not adopted law, until trilogue negotiations conclude, targeted for late 2026 or early 2027.
How Many CN Codes Will the CBAM 2028 Expansion Cover?
The exact number is not yet known. The Commission's proposal covers approximately 180 products, the Council widens that to approximately 200, and the ENVI committee position reaches an estimated 457 per trade press. These figures describe products or CN code groups, not necessarily individual 8-digit codes, so the final technical annex may list a different discrete count.
Will Downstream Products Use Full Production Emissions or Only Precursor Emissions?
Only precursor emissions, under the Commission's proposal: the embedded emissions of the steel or aluminium inputs used to make a downstream product, not the emissions from manufacturing or assembly. This principle sits in a new Annex VIII in the Commission's proposal, though the detailed calculation methodology for multi-country supply chains has not yet been finalized by any institution.
Does the Downstream Expansion Affect the Six CBAM Sectors Already in Force?
No. The existing definitive phase, covering iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen since January 1, 2026, continues unchanged regardless of how the expansion negotiations conclude. Authorization, quarterly certificate holding, and the September 30, 2027 first declaration deadline apply to the six current sectors independent of this proposal's outcome.
When Will the Final List of CN Codes Be Published?
Only once the Commission, Council, and Parliament reach a political agreement through trilogue, targeted for late 2026 or early 2027. The Parliament's plenary vote confirming its negotiating mandate is scheduled for the September 14 to 17, 2026 sitting, after which formal trilogue talks begin.