First trilogue on the CBAM downstream extension: no deal, four open issues, next round reported for November 30

Negotiators of the European Parliament and the Council met on October 20, 2026 for the first trilogue on COM(2025)989, the proposal to extend CBAM to downstream steel and aluminium goods. According to Agence Europe, both sides presented their mandates, reached no overall agreement and set the next meeting for November 30, 2026. No EU institution had published a readout as of October 23, 2026, so these are press reports. The extension remains a proposal, and nothing changes for importers today.

What was reported from the meeting

The first round produced no deal on scope and moved four technical issues to working level, according to Agence Europe.

The four issues it names are:

• A de minimis threshold for aluminium products, the question of how the 50-tonne exemption works for light finished goods
• The treatment of metal scrap, including the proposal to count pre-consumer scrap as a precursor
• Online platforms, and whether goods sold through them fall within scope
• Global default values for the added downstream goods

Contexte, whose article is behind a paywall, headlined that negotiators agreed on one point concerning the power market and moved the other issues to the next round. cbamguide.com has read only the headline and the opening line, so the content of that point is not reported here. Publicea had listed October 20 and November 30 as the planned political trilogues before the meeting.

Where the three positions stand

The institutions agree on extending CBAM to downstream steel and aluminium goods from January 1, 2028, and disagree on how many products.

Sources: the institutions' texts and Mayer Brown's note of October 7, 2026; the counts are explained on our page on the downstream product list.

One report of the meeting described Parliament's list as including chemicals and polymers and put the Council's position at 400 products. Neither matches the texts as read by cbamguide.com: no position on the downstream file includes chemicals or polymers, which are covered only by a review clause, as our page on CBAM and plastics sets out.

What it means for importers and exporters

Nothing changes until a final text is adopted, but the four open issues show where the final scope will be decided.

The proposed application date is January 1, 2028. The scrap question matters most for steel and aluminium buyers, because counting pre-consumer scrap as a precursor would bring emissions into the declaration that today fall outside it; the scrap loophole page explains the proposal. A de minimis rule for aluminium products would decide whether small importers of finished goods fall into the regime at all.

1. EU importers of steel and aluminium articles: check your CN codes against the three lists on the downstream expansion page and note which ones appear in all three.
2. Non-EU producers of downstream goods: start collecting the emissions of the steel and aluminium inputs you buy, which a final text would ask your EU customers for.
3. Everyone: treat November 30, 2026 as the next date to watch, and budget on the current scope until a text is adopted.

Timeline

Only an adopted regulation changes the scope; every date before that is negotiation.

If you need help preparing for the wider scope, describe the job on the CBAM help page and cbamguide.com introduces you by email to providers that fit.