Important legislative status: The 277 downstream product lines discussed below form part of the European Parliament’s position in the ongoing procedure 2025/0419(COD). They are proposed additions – not final, legally binding CBAM coverage. The text may change during Parliament’s plenary stage and negotiations with the Council before a regulation is adopted and published in the Official Journal.

The list of CBAM sectors covered could soon reach further industries.

The European Parliament’s Environment, Climate and Food Safety Committee (ENVI) has backed a proposed extension covering 277 downstream tariff lines. The products range from household appliances, pumps and electric motors to medical equipment, vehicle components and prefabricated buildings.

The list appears in Compromise Amendment 15 to rapporteur Mohammed Chahim’s report on the proposed revision of the Carbon Border Adjustment Mechanism, under legislative procedure 2025/0419(COD).

This is a significant development for companies that previously viewed CBAM as a regulation affecting only basic materials. If the proposal becomes law in its present form, manufacturers and importers of finished and semi-finished products containing substantial quantities of iron, steel or aluminium could acquire new carbon-reporting and financial obligations.

However, the amendment is not final EU law. The European Parliament’s Legislative Observatory currently identifies the file as awaiting Parliament’s first-reading position. It must still pass through the remaining stages of the ordinary legislative procedure, where its scope, dates and compliance rules may change.

What is changing in the CBAM sectors covered?

CBAM initially focused on a relatively narrow group of carbon-intensive goods:

• Cement
• Iron and steel
• Aluminium
• Fertilisers
• Electricity
• Hydrogen

The proposed revision would take CBAM further down the supply chain. Instead of stopping mainly at primary materials and basic metal products, it would capture selected finished goods whose production relies heavily on CBAM-covered steel or aluminium.

The policy rationale is straightforward. If imported steel is subject to CBAM but an imported machine made from the same steel is not, production could move outside the EU before the finished machine is exported back into the single market. Extending CBAM to downstream products is intended to reduce that risk.

The European Parliament describes the initiative as an extension to aluminium- and steel-intensive downstream products, accompanied by stronger measures against circumvention and changes to the treatment of emissions embedded in electricity. The Commission’s proposal envisaged applying the downstream extension from 2028, although the date remains subject to the legislative process.

Which downstream product categories are proposed for CBAM?

The 277 additions are Combined Nomenclature tariff lines, not 277 separate economic sectors. A single CN heading may cover several more detailed product lines, while similar goods may receive different treatment according to their material, design or intended use.

Compromise Amendment 15 covers products within the following broad groups.

1. Household appliances and domestic metal goods

The proposed scope reaches products commonly found in homes, commercial kitchens and heating systems, including:

• Stoves, cookers, barbecues and similar non-electric domestic appliances
• Radiators and air heaters
• Iron, steel and aluminium household articles
• Kitchenware and tableware
• Sinks, washbasins, baths and other sanitary ware
• Refrigerators and freezers
• Dishwashing machines
• Clothes-washing machines
• Certain domestic heating equipment

Relevant CN headings may include products classified under 7321, 7322, 7323, 7324, 7615, 8418, 8422 and 8450, subject to the specific subheadings included in the final annex.

2. Pumps, compressors, fans and industrial machinery

A large part of the proposed expansion concerns machinery containing significant quantities of steel or aluminium. Examples include:

• Pumps for liquids
• Air and vacuum pumps
• Compressors
• Industrial and domestic fans
• Filtering and purification machinery
• Centrifuges
• Machinery for spraying liquids or powders
• Packing, filling and sealing machinery
• Parts of covered machinery

Potentially relevant commodity codes include 8413, 8414, 8421, 8422 and 8424.

3. Boilers and heating or cooling equipment

The proposed list includes equipment used to generate, transfer or manage heat:

• Steam-generating boilers
• Central-heating boilers
• Boiler auxiliary plant
• Condensers
• Heat-treatment machinery
• Industrial heating and cooling equipment
• Heat exchangers and related equipment

Businesses should examine products classified as 8402, 8403, 8404 and 8419.

4. Lifting, loading and materials-handling equipment

The extended scope also reaches machinery used in factories, warehouses, ports and construction sites, including:

• Pulley systems, winches and hoists
• Cranes
• Forklift trucks
• Elevators and conveyors
• Other lifting, loading or handling machinery
• Parts used principally with covered machinery

Relevant commodity codes include 8425, 8426, 8427, 8428 and 8431.

5. Electric motors, generators and power equipment

Electrical machinery is another major category. The proposed tariff lines cover products such as:

• Electric motors
• Electrical generators
• Generating sets
• Parts of motors and generators
• Transformers
• Static converters
• Inductors
• Certain industrial electric furnaces and heating equipment

The principal headings include 8501, 8502, 8503, 8504 and 8514.

This means that CBAM could affect electrical-equipment businesses even though the carbon obligation would principally relate to specified iron, steel or aluminium inputs embedded in the finished product.

6. Medical devices and instruments

Selected medical and healthcare products are also included. Depending on their precise CN classification, the proposed scope may cover:

• Medical, surgical and dental instruments
• Examination or treatment equipment
• Metal-intensive medical apparatus
• Parts and accessories of specified devices

The list includes products under CN heading 9018, but companies should not assume that every product within that four-digit heading is covered. The applicable eight-digit CN subheading must be checked.

7. Motor-vehicle, railway and transport components

The proposed extension reaches selected transport-related goods, including:

• Parts and accessories of motor vehicles
• Chassis and structural components
• Selected railway or tramway parts
• Trailers and semi-trailers
• Other non-mechanically propelled vehicles
• Parts of covered transport equipment

Potentially affected commodity codes include 8607, 8708 and 8716, depending on the detailed tariff line.

Vehicle manufacturers may therefore need information not only about the weight of a component, but also about the origin and embedded emissions of its covered metal inputs.

8. Prefabricated structures and buildings

Prefabricated construction products represent one of the most visible additions. Proposed coverage includes:

• Prefabricated buildings
• Modular structures
• Metal-framed building units
• Structural components supplied as finished assemblies

These products may fall under CN Commodity Code 9406, alongside other structural iron, steel or aluminium goods already covered or proposed elsewhere in the annex.

9. Other fabricated iron, steel and aluminium products

The amendment also captures a broad range of fabricated metal goods, including:

• Fasteners
• Wire products
• Springs
• Chains
• Tanks and containers
• Cast articles
• Other articles of iron or steel
• Other articles of aluminium
• Selected tools, fittings and structural components

Commodity codes such as 7315, 7318, 7320, 7325, 7326 and 7616 are therefore especially important when reviewing the proposed list.

Why Commodity Code checking is essential

The phrase “277 downstream products” can be misleading if treated as a list of ordinary commercial product names.

CBAM coverage is determined through the EU’s Combined Nomenclature, or CN. The legal annex may specify an entire four-digit heading, a six-digit subheading or only certain eight-digit tariff lines. Two products that appear commercially similar can consequently have different CBAM treatment.

Companies should take three steps:

1. Confirm the commodity code used on the import declaration.
2. Compare the complete code – not only its first four digits -with the proposed annex.
3. Review the classification again when the final regulation and annual CN nomenclature are published.

The headings above provide a screening guide. They should not replace a product-by-product customs classification review.

What do the anti-circumvention measures mean?

Extending the CBAM sectors covered addresses one form of circumvention: shifting production from a covered basic material to an uncovered finished product.

The legislative proposal also targets practices that could weaken CBAM without necessarily changing the finished product. These may include:

• Resource shuffling: directing a producer’s lower-emission output to the EU while selling its higher-emission output elsewhere, without reducing overall emissions.
• Minor product modification: making limited changes to a good so that it falls under a CN code outside the CBAM annex.
• Artificial splitting of consignments or transactions: structuring imports to benefit improperly from exemptions or simplified requirements.
• Misstatement of material content: underreporting the quantity of covered steel or aluminium contained in a downstream product.
• Unreliable emissions data: reporting emissions figures that do not reflect the actual installation, production route or input materials.
• Changes in trade patterns: routing goods through another country or entity where there is insufficient economic justification.

The proposed rules would strengthen the Commission’s ability to investigate changes in trade flows and respond where evidence indicates that CBAM obligations are being avoided.

For businesses, anti-circumvention compliance will therefore require more than checking a customs code. Authorities may also examine product composition, sourcing arrangements, production routes, supplier relationships and changes in import patterns.

How would CBAM work for downstream goods?

Under the proposed approach, the CBAM calculation for a downstream product would focus on the relevant emissions associated with covered precursor materials contained in that product.

In practical terms, an importer could need data showing:

• The quantity of covered iron, steel or aluminium incorporated into the product
• The manufacturing installation and country of origin
• The production route used for the precursor material
• The embedded direct and, where applicable, indirect emissions
• Any carbon price already paid in the country of production
• Supporting evidence and verification records

This is more complicated than reporting emissions for a tonne of primary metal. A pump, motor, vehicle component or medical device may contain multiple metal parts sourced through several tiers of suppliers.

Importers may consequently depend on bills of materials and emissions data that their immediate suppliers do not currently collect.

Who should begin preparing?

Businesses should assess the proposal if they:

• Import any of the identified downstream products into the EU
• Manufacture covered goods outside the EU for European customers
• Supply steel or aluminium components used in those goods
• Act as indirect customs representatives
• Manage tariff classification or trade compliance for multinational groups
• Purchase imported machinery, appliances, vehicle parts or modular buildings

EU manufacturers should also monitor the file. Even where they are not the CBAM declarant, the extension could affect supplier selection, import prices, contractual requirements and the availability of emissions data.

A practical CBAM preparation checklist

Companies do not need to wait for the final vote before conducting a reversible readiness review.

Map products to CN codes

Create a list of products imported into the EU and record their full eight-digit CN codes. Flag codes appearing in the proposed downstream annex.

Identify the importer of record

Establish which group company or business partner enters each product for release for free circulation. That entity is likely to carry the principal CBAM responsibility.

Build a material-level bill of materials

Determine how much iron, steel and aluminium is incorporated into each potentially covered product. Use consistent units and retain the methodology behind each calculation.

Engage suppliers early

Ask suppliers whether they can provide installation-level emissions data for relevant precursor materials. Identify gaps several tiers down the supply chain.

Review contracts

Future supply agreements may need clauses covering:

• Emissions-data delivery
• Verification and audit rights
• Data accuracy
• Record retention
• Allocation of CBAM costs
• Cooperation following a regulatory inquiry

Test data quality

Check whether supplier data can be linked to a specific production site, production route, period and shipment. Generic environmental claims or company-wide averages may not satisfy CBAM rules.

Monitor the legislative procedure

Track amendments from Parliament and the Council, the final negotiated text, publication in the Official Journal and subsequent implementing guidance.

What happens next?

Procedure 2025/0419(COD) is being handled under the EU’s ordinary legislative procedure. The European Parliament and the Council must settle their respective positions and agree on a common text before the extension can become binding.

As a result:

• The number of tariff lines may change.
• Individual CN codes may be added or removed.
• Calculation and verification methods may be amended.
• Exemptions or thresholds may be revised.
• The proposed application date may move.

Businesses should treat the committee text as a strong compliance-planning signal, but not as the final legal annex.

Prepare now with Allied Group

The proposed addition of 277 downstream tariff lines shows how quickly the CBAM sectors covered could expand. Importers should start reviewing their commodity codes, supplier emissions data and potential CBAM costs now.

Allied Group can help with product-scope reviews, emissions reporting, supplier engagement, cost forecasting and audit-ready compliance processes.

Upcoming CBAM Training

Join Allied Group’s practical CBAM training to understand:

• Which products and CN codes are covered
• What emissions data suppliers must provide
• How CBAM costs are calculated
• How to build a compliant reporting process

Location: Liverpool
Date: 6 August 2026

Training link :

Final takeaway

The proposed addition of 277 downstream tariff lines represents a major expansion in the CBAM sectors covered. CBAM would no longer be relevant mainly to importers of cement, fertilisers, primary metals, electricity and hydrogen. It could become a direct compliance issue for businesses trading appliances, machinery, electric motors, medical devices, vehicle parts and prefabricated buildings.

The most useful first step is not to calculate a carbon charge. It is to establish whether the company’s products fall within the proposed CN codes and whether reliable information about their steel and aluminium content can be obtained.

That work will remain valuable even if the annex changes during negotiations. Businesses that understand their product classifications, supply chains and embedded-material data will be better prepared for whichever version of the extended CBAM scope ultimately becomes law.