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CBAM downstream products 2028: the scope extension, tracked.

Proposed, not adopted. The European Commission wants to extend CBAM to roughly 180 downstream, mainly steel- and aluminium-intensive product categories from 1 January 2028. As of 31 October 2026 the package sits in trilogue negotiations between Parliament, Council and Commission — the product list is still open, and part of what importers treat as a 2028 problem is already law today. This page tracks both.

The proposal

What Brussels put on the table.

In December 2025 the Commission proposed the largest expansion of CBAM since the mechanism was created. Three things are in the package.

Roughly 180 downstream product categories

Mainly steel- and aluminium-intensive goods further down the value chain than today's Annex I — proposed to enter CBAM scope from 1 January 2028.

Anti-circumvention measures

Rules targeting basic CBAM goods that are processed abroad into semi-finished or finished products so they cross the EU border outside the current scope.

→ Status: in trilogue, not law

Council and Parliament adopted their negotiating positions in 2026. The final product list and the powers attached to it are still open.

Where it stands

Moving fast, still open.

The file has moved quickly for EU legislation. The Council agreed its general approach at Ecofin on 12 June 2026, backing the extension and broadening the coverage — its position roughly doubled the number of product types compared with the Commission text. The European Parliament adopted its plenary mandate on 15 September 2026, also supporting a broader extension. Trilogue negotiations between the three institutions were under way through October 2026. Until they conclude and the amending regulation is published, no product list is final and 1 January 2028 remains a proposed date.

The practical meaning for importers: if you bring steel- or aluminium-intensive finished or semi-finished goods into the EU — fasteners, structural parts, machinery components and similar processed products — 2028 could pull you into the same machinery that importers of basic CBAM goods have run since the definitive regime started on 1 January 2026: authorised-declarant status, embedded-emissions data, an annual declaration and certificates. Many of the companies affected have never touched CBAM before, which is exactly why supply-chain screening tends to start well before the rules do — the same way EU buyers began requesting emissions data during CBAM’s transitional period, long before a single certificate was due. Our CBAM compliance team can tell you where your products stand.

For producers outside the EU nothing changes legally — the obligation stays with the EU importer, the authorised CBAM declarant. What changes is demand for data: if the extension is adopted, EU customers will be legally required to declare embedded emissions for a far wider range of goods, and the data requests will flow upstream to installations that have never been asked for them.

Timeline

From proposal to application.

DateStepWhat it means
December 2025Commission proposalExtend CBAM to roughly 180 downstream, mainly steel- and aluminium-intensive product categories from 1 January 2028, plus anti-circumvention measures
12 June 2026Council general approach (Ecofin)Backed the extension and broadened the coverage — roughly doubling the number of product types in the Council position
15 September 2026European Parliament plenary mandateBacked a broader extension as Parliament's negotiating position
October 2026Trilogue negotiationsParliament, Council and Commission negotiate the final text; the product list and delegated powers are still open
1 January 2028Proposed application dateApplies only if the regulation is adopted and published in time — not yet law

Status as of 31 October 2026. We update this page as the trilogue moves; treat any "final 2028 product list" circulating before adoption as provisional.

Already in force

Part of what people search for as "CBAM 2028" is law today. A limited set of downstream iron, steel and aluminium products — screws and bolts among them — has been listed in Annex I of Regulation (EU) 2023/956 from the start. The definitive regime has applied since 1 January 2026, the first annual declaration is due 30 September 2027, and under Implementing Regulation (EU) 2025/2621 the mark-up on default values reaches 30% for imports from 2028. Waiting for the trilogue is not a reason to ignore obligations that already exist.

Prepare now

Five moves before the list is final.

  • Screen your product portfolio against Annex I of Regulation (EU) 2023/956 and the proposed downstream categories — by CN code, not by product name. Some goods you consider finished products are already in scope.
  • Map your suppliers' installations. If the extension is adopted, your declarations will need installation-level embedded-emissions data from producers who have never been asked for it. The earlier they start, the better your numbers.
  • Price the default-value route. Default values remain allowed in the definitive period, but they carry a 30% mark-up for imports from 2028 — actual verified emissions carry none. Software such as Karbon360° turns supplier activity data into CBAM-ready emissions figures.
  • Check your declarant status. A company that would import CBAM goods for the first time in 2028 needs authorised CBAM declarant status before it can import above the 50-tonne annual threshold that exempts small importers of iron and steel, aluminium, fertilisers and cement.
  • Track the trilogue. The product list can still move in both directions, and so can the Commission's powers to amend it later — build your exposure review so it can absorb a changed list, not restart from zero.
FAQ

Frequently asked.

Which products are on the CBAM scope extension 2028 product list?
There is no final list yet. The Commission's December 2025 proposal covered roughly 180 downstream, mainly steel- and aluminium-intensive product categories; the Council's June 2026 general approach roughly doubled the number of product types; the European Parliament backed a broader extension in September 2026. The definitive list will exist only when the trilogue concludes and the amending regulation is published. Any 2028 product list you see before then is provisional.
Does CBAM apply to fasteners, screws and bolts?
Partly, already today. A limited set of downstream iron and steel products — including screws and bolts — is listed in Annex I of Regulation (EU) 2023/956 and has been covered since CBAM began. The 2028 proposal would extend coverage to a much wider range of downstream steel and aluminium goods. Check your CN codes against Annex I before assuming you are out of scope.
When does the CBAM downstream extension start?
The proposed application date is 1 January 2028. As of 31 October 2026 the extension is still in trilogue negotiations between Parliament, Council and Commission — it is not law, and both the final product coverage and the timing depend on how those negotiations conclude.
What are the anti-circumvention measures in the proposal?
They target a pattern the Commission wants to close: basic CBAM goods such as steel and aluminium are shipped to a third country, processed into semi-finished or finished products, and then imported into the EU outside CBAM's current scope. The proposal would give the EU tools to bring such processed goods back into the mechanism.
Do non-EU producers of downstream goods need to do anything yet?
They have no legal obligation under CBAM — now or under the proposal; the duty to declare and surrender certificates sits with the EU importer. But if the extension is adopted, EU customers will be legally required to declare embedded emissions for these goods, and the regulation defines exactly what they must ask their suppliers for. Producers who can answer that request with installation-level data keep the order; those who cannot answer it push their customer onto marked-up default values.
Talk to Habitat

Know where 2028 lands on your imports before it's law.

A downstream exposure screening tells you which of your goods are already in Annex I, which sit in the proposed categories, and what data your suppliers would owe you — while there is still time to prepare calmly.