Will CBAM Cover Your Product From 2028? The Downstream Extension Explained

Published 2026-10-13.

CBAM today covers basic materials: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. A European buyer who imports a finished machine part made from Indian steel pays nothing under CBAM, while one who imports the steel itself does. That gap invites a simple dodge: export the finished product instead of the metal.

The EU has proposed closing it. This article explains what is proposed, what is still uncertain, and how exporters of finished goods should prepare.

What is proposed

The EU is preparing to bring about 180 additional steel- and aluminium-intensive downstream products into CBAM, with a proposed start date of 1 January 2028. Industry reporting on the draft says it would cover fabricated metal parts, pipes and other components made largely of steel or aluminium.

The proposal was not final at the time of writing. Some member states want it sooner: Italy's industry minister called the 2028 date too distant, with the Italian steel federation present.

What else is under discussion

Reporting on the India-EU trade agreement noted that the EU is also examining whether to extend CBAM to indirect emissions from electricity for more products, possibly from the end of 2027. Today, iron, steel and aluminium are charged on direct emissions only. A change would matter most for producers on coal-heavy grids.

How a downstream product would be charged

For a covered downstream product, the embedded emissions are mostly those of the steel or aluminium inside it, plus the emissions of the processing steps. That means:

Your metal supplier's data matters most. The emissions of the wire rod, sheet or billet you bought will dominate.
Your own process adds the rest: cutting, forming, welding, heat treatment and coating, measured through your electricity and fuel use.
Default values will apply if you cannot show actual data, with the same mark-up schedule as other CBAM goods.

How to prepare now

Check your product list against the draft when the final text is published; until then, assume metal-heavy parts may be in scope.
Ask metal suppliers for installation-level emissions, as CBAM-covered producers are already being asked.
Measure your own process by product family: kWh and fuel per tonne of output.
Watch your EU customers. Importers of downstream goods will start asking before the start date, as they did for steel in 2025.

Senseible builds product-level emissions from your purchase records and energy bills, each figure linked to its source, so the same record can serve today's customer questionnaires and a future CBAM declaration. For producers already covered, see CBAM for fastener exporters in India and CBAM for aluminium exporters in India.

This is general guidance. Check the final regulation for the products and dates that apply.