CBAM: Public consultation on the extension of CBAM to downstream products

The CBAM Regulation provides for the need to assess and propose, if appropriate, an extension of the scope to so-called “downstream products” (i.e. products that are further down the value chain of the goods currently in scope). Furthermore, to prevent carbon leakage further down the value chain, the recent European Steel and Metals Action Plan stressed the need for a scope extension of CBAM to certain steel & aluminium-intensive downstream products and announced a Commission proposal to be adopted by the end of this year. 

Carbon leakage occurs if EU producers of downstream goods move production abroad to avoid increased carbon costs, or if EU buyers switch to imports from third countries with weaker climate policies. Additional anti-circumvention measures would target practices aiming to avoid the CBAM financial obligation, without due cause or economic justification. 

Concerns have furthermore been raised with the existing rules for the default values and the conditions for using actual emissions for electricity in CBAM.

On 1 July 2025, the Commission has launched a public consultation that aims to gather the opinions of all stakeholders on the policy design of CBAM’s potential scope extension to specific downstream products, anti-circumvention measures and rules for the electricity sector, as well as on their potential social, economic, environmental, and administrative impacts.

The main target audiences are EU-based and non-EU stakeholders, namely:

• companies active in the production, trading and warehousing of CBAM basic goods (including electricity) and downstream goods;
• associations of producers of CBAM basic goods (including electricity) and downstream goods;
• non-governmental organisations;
• academic institutions – in line with the Commission’s better regulation policy to develop initiatives informed by the best available knowledge, we particularly invite researchers and academic organisations to submit relevant published and pre-print scientific research, analyses and data;
• public authorities, including customs authorities; and
• trade unions.

You can share your feedback on this initiative until 26 August 2025.

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