CBAM: The extension is extending

On 1 January 2026, the European Union’s (EU) Carbon Border Adjustment Mechanism (CBAM) entered fully into force, covering 569 products of aluminium, cement, electricity, fertilisers, iron and steel, and hydrogenⁱ. Only a few weeks before that, on 17 December 2025, the European Commission (Commission) had published a proposal to extend the CBAM-product list to 749 from 1 January 2028 onwardsⁱⁱ.

As required in the EU ordinary legislative procedure, the Council of the European Unionⁱⁱⁱ (Council, 12 June 2026) and the responsible committee in the European Parliament^iv (the Committee on Environment, Public Health and Food Safety (ENVI), 6 July 2026) have now also published their respective positions on the extension of the list of CBAM-products for 2028 (Figure 1).

In this brief article, we summarise the most important similarities and differences in these proposals to provide insights into which products are more and less likely to be confirmed in the trilogue negotiations between the Commission, Council, and Parliament later this year – and to be in the scope of CBAM starting 2028^v.

Figure 1: The product scope of CBAM is likely to be extended significantly

Note: Author’s calculation and visualisation based on European Union (2023)^vi, European Commission (2025)^vii, Council of the European Union (2026)^viii, and European Parliament ENVI Committee (2026)^ix. *This represents the proposal of the ENVI Committee.

For businesses, CBAM results in both direct and indirect additional costs for importing. The direct costs are primarily linked to the purchasing of CBAM certificates to partially offset embedded emissions. The indirect costs are related to the increased need to engage with suppliers, to collect and process data, and to establish responsibilities for reporting as well as the strategic planning of imports to reduce financial exposure.

As mentioned, CBAM currently applies to 569 products at the 8-digit CN level (Combined Nomenclature). In the beginning of the transitional phase in October 2023, the list of CBAM products was actually considerably longer and covered 753 products, 184 of which got invalided later on^x. The Commission’s proposal to extend the list of CBAM-products refers to the currently applicable list.

In total, the Commission proposes to extend the list of CBAM-products by an additional 180 products. Importantly, this list includes many downstream products of machinery and mechanical appliances (CN chapter 84); motor vehicles (CN chapter 87); articles of iron and steel (CN chapter 73); electrical machinery (CN chapter 85); furniture (CN chapter 94); optical, measuring and medical instruments (CN chapter 90); as well as articles of base metal (CN chapter 83) and copper (CN chapter 74).

The Council proposes to extend the Commission’s proposed extension list by an additional 197 products. The large majority of these products fall under the same product groups (CN chapters) but the Council does also add new products including tools and cutlery (CN chapter 82). Interestingly, the Council also proposes to remove three products from Commission’s extension proposal.

The Parliament has not yet published its final position on the extension of the product list. However, given that the ENVI committee is responsible for CBAM, it can be assumed that its position plays an important role in forming the Parliament’s position during the September 2026 plenary session. In total, the ENVI proposes to add 283 products to the Commission’s extension proposal. Again, most of the added products fall into the same product groups (CN  chapters). That said, the ENVI additionally proposes to add more iron and steel products (CN chapter 72); aluminium articles (CN chapter 76); organic chemicals (CN chapter 29); and railway equipment (CN chapter 86).

The Council’s and the Parliament’s proposals are based on the Commission’s proposal and therefore add on top of this. In other words, most of the 180 additional products proposed by the Commission are likely to be included in the final product extension list to be decided in the trilogue. But what about the products that are proposed by either the Council or the Parliament in addition?

The Council, for example, proposes to include 46 additional products of machinery and mechanical appliances (CN chapter 84); tools and cutlery (CN chapter 82); and electrical machinery (CN chapter 85) that are not included in the Parliament’s proposal. In contrast, the Parliament’s proposal includes 129 products that are not included in the Council’s proposal, mainly including products of machinery and mechanical appliances (CN chapter 84); electrical machinery (CN chapter 85); and optical, measuring and medical instruments (CN chapter 90) but also other product groups such as organic chemicals (CN chapter 29).

That said, there are also 154 products that are proposed both by the Council and the Parliament and which therefore, arguably, have a higher chance to be included in the final CBAM product list.

Figure 2: Zooming into the extension proposals of the Commission, the Council, and the Parliament

Note: Author’s calculation and visualisation based on Author’s calculation and visualisation based on European Union (2023)^xi, European Commission (2025)^xii, Council of the European Union (2026)^xiii, and European Parliament ENVI Committee (2026)^xiv. *This represents the proposal of the ENVI Committee.

Given the schedule of the legislative process, businesses can expect to see the final, extended list of CBAM-products to be published by the end of the year. However, businesses are well advised to start preparing now and

• Assess the proposed product codes and their relevance for the supply and value chains
• Evaluate whether additional products may elevate imports above the 50-tonne threshold
• Calculate proxy default values and benchmarks for the new products
• Estimate and forecast the financial exposure to CBAM and its extended product scope
• Explore decarbonisation strategies to reduce the level of carbon emissions and the associated costs

Please reach out to learn in detail about the products included in the different legislative proposals and to discuss the required actions outlined above.