Sittings · Document

OPINION (COM(2025)0989 – C100352/2025 – 2025/0419(COD)) 2026-06-23

On the proposal for a regulation of the European Parliament and of the Council on amending Regulation (EU) 2023/956 as regards the extension of its scope to downstream goods and anti-circumvention measures

Committee on International Trade · Rapporteur: Lynn Boylan

✦ In short · AI summary of this text, generated 18 Sept 2026

The Committee on International Trade gives its opinion on the Commission proposal to extend the CBAM Regulation to downstream goods and add anti-circumvention measures. It proposes amendments to support developing countries, including technical assistance, reporting on CBAM impacts, a possible exemption of least developed countries from financial obligations, and at least 25% of CBAM revenues for international climate finance. It deletes the proposed Article 27a on serious and unforeseen circumstances and the related urgency procedure, and tightens anti-circumvention rules. It adds rules on outermost regions, electricity emission calculations, scrap and aluminium default values, guarantees for small and medium-sized enterprises, and deadlines for the downstream scope extension.

Committee position. The committee proposes amendments to the Commission proposal, focusing on international support for developing countries, deleting Article 27a, strengthening anti-circumvention, and adding rules on outermost regions, electricity, aluminium and deadlines.

Key points

  1. The Commission should give technical assistance to developing countries, especially lower-middle-income countries and least developed countries, on monitoring, reporting and verification, emissions accounting and carbon pricing.
  2. The Commission should regularly report on CBAM impacts on developing countries' economies, their ability to comply, and its contribution to industrial decarbonisation and climate policies.
  3. Least developed countries could be exempted from CBAM financial obligations while keeping reporting requirements, and simplified procedures should be considered for small and medium-sized enterprises in lower-middle-income and least developed countries.
  4. The Commission should direct an amount equivalent to at least 25% of CBAM revenues to additional international climate finance and promote transfer of low-emission technologies.
  5. The proposed Article 27a on serious and unforeseen circumstances and the related urgency procedure are deleted.
  6. The Commission shall monitor circumvention practices continuously and may require evidence on declared installations, including mill certificates for certain iron and steel products.
  7. A temporary derogation from the mark-up for certain downstream goods is allowed for two calendar years from the application of the relevant implementing act.
  8. From 1 January 2026, the Regulation shall not apply to goods in outermost regions under cumulative conditions, with a declaration of compliance required.
  9. Emission calculation rules for imported electricity should reflect country- and region-specific energy mixes and recognise renewable electricity, with revised default values published by the Commission.
  10. Simplified approaches with conservative default values are provided for scrap use in unwrought aluminium and for aluminium scrap and waste streams where recycled content cannot be determined.
  11. Guarantee requirements for authorised CBAM declarants shall consider the size of the declarant, especially small and medium-sized enterprises, and be proportionate to the actual financial risk.
  12. The Commission shall adopt implementing and delegated acts, adapt the CBAM registry, publish guidance and report on preparedness for the downstream scope extension by 30 June 2027, 30 September 2027, 30 June 2027 and 31 March 2027 respectively.

Who is affected

  • Developing countries, especially lower-middle-income countries and least developed countries, which would receive technical assistance and reporting on CBAM impacts.
  • Small and medium-sized enterprises in lower-middle-income and least developed countries, which could benefit from simplified procedures.
  • Importers and authorised CBAM declarants, who face evidence requirements, guarantee rules and monitoring of circumvention risks.
  • Outermost regions, which would be exempt from the Regulation for certain goods from 1 January 2026.
  • The north of Ireland, Ireland and Britain, regarding the application of CBAM and the linking of emissions trading systems.

Figures and deadlines

  • at least 25% of the CBAM revenues towards additional international climate finance
  • From 1 January 2026, exemption for goods in outermost regions
  • no mark-up for certain downstream goods for a period of two calendar years from the date of application of the relevant implementing act
  • within three months from the collection of the findings, initiate the procedure for delegated acts on anti-circumvention
  • Before 1 January 2028 the Commission shall present a report on extending the scope to additional goods
  • no later than 30 June 2027, adopt implementing and delegated acts and publish guidance for downstream goods
  • no later than 30 September 2027, adapt the CBAM registry for downstream goods
  • no later than 31 March 2027, report to the European Parliament and the Council on preparedness

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