Consultation also addresses anti-circumvention measures and electricity sector rules
On 1 July 2025, the European Commission launched a public consultation to gather stakeholder feedback on potential extensions to the Carbon Border Adjustment Mechanism (CBAM). The initiative explores expanding CBAM’s scope to include specific downstream products, introducing anti-circumvention measures, and revising rules for the electricity sector.
Why the Scope Expansion Is Under Consideration?
Currently, CBAM applies to high-emission goods such as steel, aluminium, cement, and electricity. However, there is growing concern about carbon leakage further down the supply chain — particularly in steel- and aluminium-intensive downstream products.
Carbon leakage can occur when EU producers shift operations abroad to avoid higher carbon costs, or when buyers turn to imports from countries with less stringent climate policies. To address this, the European Steel and Metals Action Plan has called for the inclusion of downstream products in CBAM, with a Commission proposal expected by the end of 2025.
Anti-Circumvention and Electricity Sector Concerns
The consultation also addresses the need for stronger anti-circumvention rules. These would aim to prevent practices that artificially avoid CBAM obligations without valid economic reasons.
Additionally, the Commission seeks input on the default values and conditions for using actual emissions data in the electricity sector — an area where stakeholders have raised concerns over the current methodology.
Who Should Participate?
The consultation invites feedback from a broad range of stakeholders, including:
• Companies and associations involved in CBAM-regulated and downstream goods (including electricity)
• NGOs and trade unions
• Academic institutions and researchers
• Public authorities and customs agencies
Researchers are especially encouraged to submit scientific data or analysis, whether published or pre-print, in line with the Commission’s evidence-based policymaking approach.
How to Contribute?
Stakeholders can submit their feedback until 26 August 2025 via the European Commission’s online consultation portal.
This is a key opportunity for industry, civil society, and experts to shape the future of CBAM — particularly as the EU intensifies efforts to align trade policy with its climate goals.
Reach out to our regulation experts on chemical and product regulatory compliances