As part of the European Green Deal, the European Commission is preparing another update to the CBAM Regulation. This time, it aims to expand the mechanism to include downstream products , as well as new anti-circumvention measures and changes to emissions reporting rules for the electricity sector.
📅 Planned date of adoption of new regulations: Q4 2025.
📢 Public consultations run until 26 August 2025. Have your say →
Why does the Commission plan to expand CBAM?
The CBAM (Border Adjustment Mechanism for CO₂ emissions) is intended to prevent carbon leakage – i.e. the relocation of production outside the EU to countries with less stringent climate policies.
Currently, the mechanism covers six sectors: cement, iron and steel, aluminum, fertilizers, hydrogen, and electricity . However, according to the Commission, the risk of downstream carbon leakage , or the transfer of emissions to subsequent stages of the supply chain, is growing, for example, through the import of semi-finished products or components made from raw materials covered by the CBAM.
So what exactly does the proposal provide?
1. Extension of CBAM to derivative products
The Commission intends to include selected derivative products containing steel, aluminium or other CBAM “base” raw materials in CBAM. The selection is to be based on:
- the risk of carbon leakage,
- the intensity of emissions built into the product,
- technical feasibility.
2. New anti-circumvention measures
The Commission sees a growing risk of 'circumventing' CBAM, for example through minor modifications of goods outside the EU that formally exclude them from regulation. Planned actions include:
- additional reporting obligations,
- control of production chains.
3. Changes for the electricity sector
Currently, the CBAM for imported electricity is mainly based on default values. The Commission is considering:
- modification of emission values (e.g. indicators other than just CO₂),
- simplification of the conditions for using real data (e.g. by facilitating PPAs or transmission networks),
- better taking into account the “green energy mix” of third countries.
What will be the implications for businesses?
➕ Benefits:
- a stronger impetus for decarbonization,
- fairer competition conditions for producers in the EU,
- greater effectiveness of CBAM as a climate instrument.
➖ Challenges:
- new reporting and administrative obligations for importers,
- possible cost increases for products with a high content of base materials,
- the need to adapt reporting systems and processes.
Co dalej?
The European Commission has launched a public consultation , to which it invites:
- producers and importers of CBAM goods and related products,
- industry organizations, trade unions, NGOs and public administration,
- scientific community – including universities and research institutes.
🗓 Deadline for submitting opinions: 26 August 2025 📝 The consultation form is available at: https://europa.eu/!gTqNV9
How can we help with Green Reporting?
In Green Reporting we already support importers and producers in:
- collecting data from suppliers outside the EU,
- calculating embedded emissions in accordance with CBAM guidelines,
- preparation of quarterly reports,
- implementing IT tools to facilitate reporting and communication.
Expanding CBAM is not only a challenge, but also an opportunity to build a competitive advantage based on transparency and sustainable development.
🟢 Contact us if your company might be affected by the new CBAM obligations. We'll help you prepare today.
📧 office@greenreporting.eu 🌐 www.greenreporting.eu