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CBAM goes downstream: what importers of steel and aluminium goods must do before 2028

How the proposed extension of the carbon border adjustment mechanism would change scope, cost and compliance for EU importers – and the decisions to make now

Erika Besusparienė
Head of MBA programme 'Customs Process Management', Associate Professor, Faculty of Bioeconomy Development, Vytautas Magnus University, Lithuania
Irma Juodienė
PhD candidate, Faculty of Bioeconomy Development, Vytautas Magnus University
Published 02 Aug 2026·Updated 20 Sep 2026
CBAM goes downstream: what importers of steel and aluminium goods must do before 2028
Adobe Stock
Topic spotlight

Editorial update: on 15 September 2026 the European Parliament took its position and would go further, to 457 product lines. The file now goes to trilogue.

Importers that have only recently adapted to CBAM on raw steel and aluminium now face a further change. The Council's general approach of 12 June 2026 would extend the carbon border adjustment mechanism to around 180 downstream products - finished and semi-finished goods with a high steel or aluminium content - from 1 January 2028. Prefabricated steel greenhouses (CN 9406 90 31) are one example on the list. This article explains what the extension would cover, how embedded emissions in downstream goods are calculated from their precursors alone, when the financial obligations take effect, and what the cost and administrative burden could look like for a high-volume importer. It is written for importers, customs representatives and compliance teams sourcing metal-containing goods from third countries, and sets out the supplier-data, classification and budgeting decisions worth making now, while the final scope is still open.

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