Proposal COM(2025) 419 · not yet adopted

The CBAM 2028 downstream expansion — proposed, not yet law

The Commission wants to extend CBAM to roughly 180 manufactured goods from 1 January 2028. It hasn't been adopted yet, and the details can still change.

By Sridhar Mothe · Founder, CarbonAtlas

Last verified: 02 September 2026

This is a proposal, not current law. Everything below describes what the European Commission has put forward — not a rule that applies today. Don't plan a declaration or budget around it as settled until it's formally adopted.

What's actually being proposed

On 17 December 2025, the European Commission published proposal COM(2025) 419, which would extend CBAM to roughly 180 downstream products — manufactured goods that incorporate steel or aluminium already covered by CBAM, rather than raw material imports.

Examples the Commission's own proposal cites:

  • Engines and vehicle components
  • Refrigerators and other domestic appliances
  • Heat-pump components
  • Fabricated metal goods and machinery

If adopted, importers of these newly-covered goods would need to purchase and declare CBAM certificates from 1 January 2028.

Where it actually stands

StageStatus
Commission proposal published17 December 2025 — COM(2025) 419
Council of the EU positionAgreed 12 June 2026
European Parliament positionExpected September 2026
Trilogue negotiationsFollows Parliament's position
Formal adoptionTargeted for 2027 (not guaranteed)
Proposed effective date1 January 2028, if adopted on schedule

The final product list and emissions-attribution methodology are determined during trilogue — the scope described above is the Commission's opening proposal, not necessarily the final adopted text. Check back closer to formal adoption before treating any specific product list as locked.

What to do while this is still pending

If you import goods that would fall under this expansion, it's reasonable to start tracking the products and suppliers involved now — but treat any 2028 obligation as planning, not compliance. CarbonAtlas will update this page and add scope-detection for these product categories once the regulation is actually adopted, not before.

Frequently asked questions

No. As of this page's last-verified date, it is a Commission proposal (COM(2025) 419, published 17 December 2025) moving through the EU's ordinary legislative procedure — it has not been formally adopted by the Council and European Parliament yet.

See how CarbonAtlas applies this automatically