Three CBAM industry reactions in 15 days have drawn the battle lines for the European Parliament's September plenary vote on the CBAM review. ArcelorMittal wants the mechanism extended to downstream steel products (July 1), European Aluminium wants the definitive period paused for aluminium unless two loopholes are fixed (July 8), and the Irish Farmers' Association (IFA) wants the deleted fertilizer emergency safeguard restored (July 15). Each demand targets a variable that determines import costs from 2027 onward: product scope, the de minimis threshold, and a possible suspension clause.
The aluminium and fertilizer statements respond directly to the review position adopted by Parliament's environment committee on July 6. ENVI's CBAM review position expands downstream scope to more than 400 CN codes, tightens anti-circumvention rules, and deletes the emergency brake. ArcelorMittal published five days before that vote, but its downstream demand targets the same review file. The full Parliament votes on that position in September. Nothing in the committee text is law yet; the review changes Regulation (EU) 2023/956 only once Parliament and Council agree a final text in trilogues.
Who wants what before the September plenary
Between July 1 and July 15, 2026, one steelmaker, one industry association, and one farm organization published formal CBAM demands, and no two of them want the same thing. The table below compares the three positions.
| Voice | Date | Sector | Core complaint | Demand |
|---|---|---|---|---|
| ArcelorMittal | July 1, 2026 | Steel | Imported steel derivatives, especially electrical steels in motors and generators, remain unprotected | Extend CBAM and TRQs to downstream products; prioritize EU-made motors and generators in public procurement |
| European Aluminium | July 8, 2026 | Aluminium | Post-consumer scrap loophole and 50-tonne de minimis threshold left unresolved by ENVI | Default carbon values on all aluminium scrap, a redesigned Temporary Decarbonisation Fund, or a pause of the definitive period for aluminium |
| Irish Farmers' Association | July 15, 2026 | Fertilizers | ENVI deleted the safeguard allowing temporary suspension of the CBAM levy on fertilizers | Restore the safeguard at the September plenary |
Steel interests want CBAM to cover more products, aluminium producers want it corrected or delayed, and farm organizations want a legal way to switch it off temporarily. Parliament can accommodate any of the three through plenary amendments, which is why the lobbying concentrates on September.
ArcelorMittal: extend CBAM and TRQs to downstream steel products
ArcelorMittal welcomed the January 1, 2026 CBAM start and the steel tariff-rate quota (TRQ) regime that took effect on July 1, 2026, but called both insufficient because imported steel derivative products remain outside their protection. The company described the two measures as "an important first step toward creating a more level playing field for Europe's low-carbon steel industry" in a statement reported by SteelOrbis, while Paul Brettnacher, chief marketing officer at ArcelorMittal Europe Flat Products, warned that "the growing volume of imported steel derivative products that remain outside the scope of both CBAM and TRQ is undermining the effectiveness of the EU's trade and climate policies."
The gap the company points to sits in electrical steel. Nearly two-thirds of the non-grain-oriented electrical steels (NGOES) used in Europe for new electric motors and generators are now imported from outside the EU, according to the company, without facing equivalent carbon or trade measures. ArcelorMittal wants CBAM and the TRQs extended along the entire NGOES value chain, from first-transformation derivatives such as laminations, stators, and rotor cores through to finished electric motors and generators, and wants EU-made motors and generators prioritized in public procurement and in wind and electric vehicle funding programs.
The demand lands on prepared ground. The Commission's downstream proposal, COM(2025)989, would extend CBAM to derivative steel and aluminium products from January 1, 2028, subject to approval, and ENVI pushes the product list past 400 CN codes; the institutional positions are mapped in the CBAM downstream expansion comparison. The scope decision determines which shipments need embedded emissions data from 2028, and the CBAM impact on steel exporters already varies sharply by production route.
European Aluminium: fix the scrap loophole and the 50-tonne threshold, or pause aluminium
European Aluminium said on July 8, 2026 that the ENVI vote failed to fix the post-consumer scrap loophole and the ill-suited 50-tonne de minimis threshold, and Director General Paul Voss asked the Commission to pause CBAM's definitive period for aluminium if both stay unresolved before the September plenary. "A CBAM that can be avoided through resource shuffling and an ill-suited threshold will not protect European industry," Voss said, adding that CBAM "will lead to an overall increase in costs for European producers, while importers can source their raw material in markets that do not face such carbon costs."
The CBAM aluminium scrap loophole works through declarations. Metal remelted from post-consumer scrap carries near-zero embedded emissions under current rules, so exporters can shuffle resources by routing scrap-declared aluminium to the EU while selling primary-based metal elsewhere, backed by scrap declarations that verifiers struggle to test. The association estimates that roughly one quarter of global aluminium production could keep avoiding European carbon costs if the gaps stay open.
The association's three demands are listed below.
- Apply default carbon values, set at the footprint of primary aluminium production, to all unwrought aluminium including scrap-based metal until verification systems prove reliable
- Rework the mass-based 50-tonne de minimis threshold, which ignores aluminium's high value-to-weight ratio; in the association's example, aluminium doors for a 200-room hotel renovation total 9.2 tonnes, well under the exemption line
- Redesign the Temporary Decarbonisation Fund so it covers downstream products more broadly and compensates both direct ETS costs and CBAM-driven raw material cost increases
If the plenary delivers none of this, European Aluminium wants the Commission to stop the clock: pause the definitive period for aluminium and halt the free allowance phase-out until the changes are in place and the competitive impact is assessed. Free allocation stands at 97.5 percent in 2026, with a CBAM factor of 2.5 percent, so a pause now would freeze the mechanism while certificate costs are still small. The request overlaps with the separately tabled ETS Phase 5 revision that slows the CBAM phase-in, which would reintroduce 15 percent of the phased-out free allocation from 2028 and push the full phase-out to 2038. The levy also prices direct emissions and PFCs only, not indirect electricity emissions, as the CBAM aluminium rules set out.
IFA: restore the fertilizer emergency safeguard
IFA environment chair John Murphy called on July 15, 2026 for Irish MEPs and the European Parliament to restore the emergency safeguard that would allow temporary suspension of the CBAM levy on fertilizers during exceptional market disruption. ENVI voted to delete the clause from its review position. "Removing the only emergency safeguard that would have allowed for its temporary suspension during periods of exceptional market disruption leaves farmers exposed when they are most vulnerable," Murphy said in remarks reported by the Irish Farmers Journal, calling retention "a practical and proportionate measure" and arguing that "environmental policy cannot ignore the economic realities of producing food."
The cost exposure behind the demand is direct. Fertilizer is one of the largest input costs for Irish farms, particularly in tillage, and urea carries roughly 2.5 tCO₂ of embedded emissions per tonne. At the Q2 2026 certificate price of €75.28/tCO₂e, a fully phased-in CBAM would add about €188 per tonne of urea; at the 2026 CBAM factor of 2.5 percent the added cost stays under €5 per tonne, but it rises every year as free allocation phases out. The full calculation chain, including N₂O and indirect emissions, is set out in the CBAM fertilizers guide.
What the battle lines mean for the September vote
The September plenary vote sets Parliament's negotiating position, not final law, so downstream scope, the de minimis threshold, and the fertilizer safeguard can all still move during trilogues with the Council. Parliament could widen steel scope, tighten scrap rules, and restore the safeguard in a single set of amendments; whether it does depends on plenary majorities the July statements are designed to build.
Three checkpoints follow for compliance teams.
- Watch the plenary vote on the CBAM review in September, which decides whether the emergency safeguard returns and how far past 400 CN codes the downstream list goes
- Watch the parallel member state September vote on carbon price deductions, which decides which foreign carbon prices count against CBAM bills
- Watch the trilogues that follow, because only the agreed final text amends Regulation (EU) 2023/956
None of the three demands changes current obligations. The definitive phase runs, certificate sales open February 1, 2027, and the first annual declaration is due September 30, 2027 covering calendar year 2026. What September decides is how wide, and how adjustable, the system becomes after that.