Sittings · Document

OPINION (COM(2025)0989 – C100352/2025 – 2025/0419(COD)) 2026-06-24

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

Committee on Industry, Research and Energy · Rapporteur: Massimiliano Salini

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

The Committee on Industry, Research and Energy gives its opinion on the Commission proposal to extend the Carbon Border Adjustment Mechanism (CBAM) to downstream goods and add anti-circumvention measures. It proposes widening the scope to downstream steel and aluminium products, adding CN codes to the Annexes, and broadening the definition of circumvention. It wants mandatory default values for high-risk goods and countries during a transition period, and only existing exemption procedures kept. It proposes excluding pre-consumer steel scrap from CBAM precursors and rejecting the Commission's approach to pre-consumer scrap.

Committee position. The committee proposes amendments to the Commission proposal, including extending CBAM to downstream goods, broadening circumvention rules, introducing mandatory default values for high-risk goods, and excluding pre-consumer steel scrap from CBAM precursors.

Key points

  1. The opinion suggests widening CBAM to downstream goods, since steel and aluminium are used in strategic value chains and could be circumvented.
  2. It proposes broadening the definition of circumvention and significantly shortening the Commission's processing times.
  3. It proposes adding CN codes to the Annexes to extend the scope to downstream products.
  4. Exclusion of goods by the Commission should be a last resort and for a limited period, to maintain legal predictability.
  5. In high-risk sectors such as steel, actual data should not be permitted where low-carbon volumes could be reallocated.
  6. The opinion proposes mandatory default values during a transition period for high-risk goods and countries.
  7. It takes a flexible, targeted approach to identify imports at risk of circumvention while limiting complexity and administrative burden.
  8. It opposes new emergency procedures for removing third countries from CBAM scope and wants only existing exemption procedures maintained.
  9. It notes the Commission's generic concept of 'abusive practices' lacks directly applicable countermeasures and may be ineffective for many sectors.
  10. It proposes excluding pre-consumer steel scrap from CBAM precursors and rejecting the Commission's proposal on steel scrap.

Who is affected

  • Steel and aluminium producers and importers, who would face extended CBAM scope and new traceability requirements.
  • Electric arc furnace steel industry, which would be penalised if pre-consumer scrap is treated as blast furnace material.
  • Third countries with electricity market integration, which could conclude Memoranda of Understanding for CBAM exemptions.
  • Ukraine, whose economy and recovery the Commission should monitor for CBAM impact and possible temporary exemption.

Figures and deadlines

  • Delegated acts within three months after finding sufficient evidence of abusive practices.
  • Default values for a transitional period of at least three years to prevent abusive practices.
  • Commission decision on outermost region exemption requests within two months of submission.
  • Delegated acts no later than two months of finding sufficient evidence of high risk of abusive practices.
  • Delegated acts at the latest within three months from collection of findings on anti-circumvention.
  • Article 20(1), (3), (4) and (5) shall apply from 1 February 2027.
  • Points 1 and 6 of Annex II shall apply from 1 January 2026.
  • Article 1(6)(a), Article 1(8)(a), (b), (c), Article 1(24) and point 2 of Annex II shall apply from 1 January 2028.

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