CBAM downstream extension: what's proposed and what isn't law
A proposal to extend CBAM to downstream goods (cars, white goods, machinery) was in trilogue as of October 2026. It's not law yet — here's the state of play.
Published 19/10/2026 · Facts checked on 2026-10-18
Answer box
As of October 2026, a legislative proposal to extend CBAM to downstream goods (cars, white goods, machinery, assemblies containing steel and aluminium) is in trilogue between the Commission, the Parliament and the Council. It is not law. Importers of downstream goods should not change their 2026 or 2027 compliance plans based on it.
Why the extension is being discussed
- Downstream goods bypass today’s CBAM: a car containing 1 tonne of steel pays no CBAM when imported.
- Steelmakers argue this creates “carbon leakage” at the finished-goods level.
- Downstream industry groups argue the compliance burden on complex BoMs would be very high.
What’s being discussed (not yet in final text)
- Scope. Likely limited to specific HS chapters (automotive, white goods).
- Data path. Importers would need to source upstream steel and aluminium data via the supply chain.
- Phase-in. Likely over several years.
- Default values. Would need new reference tables.
Our stance
We are not pre-building for downstream until there is a published final text. When there is, we will update the rule tracker the same day.