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

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 file is still pre-trilogue.