CBAM downstream expansion: the 180-product proposal explained

Someone forwards you a list of 180 products and asks whether your goods are now in CBAM scope. The list is real, but the obligation does not exist yet. It comes from a Commission proposal to extend CBAM to more downstream steel and aluminium products.

On 6 July 2026 the European Parliamentary Research Service (EPRS) published a briefing that explains this proposal. The proposal would also address circumvention and change parts of the electricity methodology. The briefing is useful because it puts the proposal, the institutional background and stakeholder views in one document.

What the briefing is and is not

The briefing is research, not a legal text. EPRS research is not legislation, and it does not represent an official position of the European Parliament. This article summarises EPRS briefing PE 789.314, published 6 July 2026, so keep that status in view as you read the figures below.

Which proposal the briefing examines

The briefing concerns procedure 2025/0419(COD) and Commission proposal COM(2025) 989 final, dated 17 December 2025.

According to EPRS, the proposal would add 180 downstream products, with an average steel or aluminium content of 79%. EPRS reports that about 94% of those products are industrial supply-chain goods, and that the remainder include household products.

These figures describe the proposal, and they do not change the current goods scope. Their immediate value for a business is scenario planning: compare the proposed categories with your product portfolio. Do not recode goods as CBAM-covered because they appear in a proposal or in a research briefing.

The proposal is wider than a product list

The EPRS summary covers more than downstream products. It discusses proposed provisions on EEA and EFTA treatment, electricity-market integration and abusive practices. It also covers declaration composition data, precursorPrecursorUpstream CBAM good consumed as input to a complex-good process; listed per route; quantities always monitored per Annex II pt E. emissions and installation evidence. Financial-capacity guarantees and internal-market monitoring or emergency removal are part of it too.

The briefing also explains that the proposal would expand Annex I and change the Annex IV electricity method. A new Annex VIII would identify non-CBAM precursor goods or gases.

Downstream expansion is therefore not only a customs-classification exercise. If the legislation is adopted, more supply chains could need product composition, precursor information and emissions evidence. The final legal design may still differ from the proposal described.

The policy debate in the briefing

EPRS recounts consultation support for two things: addressing downstream carbon leakageCarbon leakageThe relocation of production — and its emissions — outside the EU to avoid EU carbon costs; the risk CBAM exists to prevent by pricing imports' embedded emissions on a par with EU production. and circumvention, and revisiting the criteria for electricity default or actual values. The briefing also places the proposal alongside earlier Parliament resolutions, institutional positions and stakeholder viewpoints.

That background explains the policy reasons, but it does not settle the outcome. A briefing can describe the arguments accurately and still differ from the position Parliament finally adopts.

Where the procedure stands

The procedure moved after the briefing was written, and the table below shows each step with its date.

At the 16 July 2026 cutoff, the procedure was recorded as awaiting Parliament's position at first reading. EPRS reported an ENVI vote on 6 July 2026 and an indicative plenary date of 14 September 2026.

The plenary vote took place on 15 September 2026. Parliament adopted its amendments, P10_TA(2026)0276, but it took no vote on the legislative resolution. The matter was referred back to the committee for interinstitutional negotiations. Parliament has therefore not closed its first reading, and no final text exists.

What it means for importers

Nothing changes in what you declare today, because the downstream products sit in a proposal and not in law. The proposal is useful as an outlook scenario, and it should stay separate from current-law scope and from declaration decisions.

What to do

Use a two-column register to keep the separation visible.

• Put obligations under the law in force in column one.
• Put possible changes under proposal 2025/0419(COD) in column two, and update it as Parliament and Council positions develop.
• Map the downstream products the proposal could affect, and find where your steel or aluminium composition data is held.
• Note which suppliers could provide precursor and installation evidence.

Move an item into column one only after the legal act is adopted, published and applicable.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article explains a research briefing on a legislative proposal. It is not legal, tax or customs advice.