CBAM extension — downstream goods and anti-circumvention
COM(2025) 989 final, 2025/0419 (COD)
Direction
44 burden · 17 benefit
Status
61 mixed
Channel
53 direct · 0 reached · 8 no sector
The platform holds 61 measures for CBAM extension: 44 imposing a burden, 17 conferring a benefit. Of these, 61 from a file spanning both; 53 arrive directly, 0 through a channel, 8 apply by size or activity rather than by sector.
Reach
Names 6 sectors, reaches 8
CBAM extension names 6 sectors; 2 more are — automotive, waste and landfill — reached without being named, by another act and supply chain.
Automotive — reached by 7 measures, via another act and supply chain
Waste and landfill — reached by 2 measures, via supply chain
Connections
This file in the graph
Every line is an edge in the platform's knowledge graph — acts this file amends or its measures cite, and the sectors those measures apply to. Counts are computed at build time and checked against the graph.
Amends (1)Cites (2)Sectors (8)
40 measures
Steel
SCP-01CBAM applies to processed products made from Annex I goods under inward processing where they are re-exported to Norway or Iceland, bringing those consignments into the CBAM regime.Importers and authorised CBAM declarants of processed products re-exported to Norway or Iceland · BusinessesRequirementSCP-02Comply with the CBAM regime for goods originating in third countries that were previously released for free circulation in the customs territory of an EFTA State that has incorporated the CBAM.Customs declarants importing goods previously released for free circulation in a CBAM-integrated EFTA State · BusinessesSimplificationSCP-03Bear responsibility for having documentation proving prior release for free circulation in an EFTA State available at the moment the customs declaration is lodged.Customs declarants relying on the EFTA prior-free-circulation exemption · BusinessesRequirementSCP-04A new 'Combined metal products' category enters CBAM scope, pulling downstream steel- and aluminium-containing manufactured goods into the embedded-emissions declaration and certificate-surrender regime for the first time.Importers and authorised CBAM declarants of downstream steel- and aluminium-containing goods · BusinessesRequirementSCP-06Comply with CBAM for a good whose inclusion in Annex I is causing severe harm to the Union internal market through serious and unforeseen price effects.Importers of goods withdrawn from Annex I under the safeguard · BusinessesSimplificationDECL-01Include in the CBAM declaration evidence that the imported goods were actually produced at the declared installation and at the declared time of production.Authorised CBAM declarants for goods flagged for supply-chain traceability risk · BusinessesRequirementDECL-02Where a goods/origin combination is designated high-risk for abusive practices and actual emissions are claimed, prove in the declaration that the abuse risk has not materialised.Authorised CBAM declarants claiming actual emissions for high-risk goods/origin combinations · BusinessesRequirementDECL-03Report total embedded emissions per tonne of goods (or per MWh for electricity), and have them verified where actual emissions are supplied by the operator through the CBAM registry.Authorised CBAM declarants · BusinessesRequirementDECL-05Produce, on request during review of the CBAM declaration, evidence that the imported goods were produced at the installation named in the declaration.Authorised CBAM declarants determining embedded emissions on actual emissions · BusinessesRequirementDECL-06Keep the full underlying records required to calculate embedded emissions, rather than the information actually disclosed to the declarant under Art. 10(7).Authorised CBAM declarants · BusinessesSimplificationCALC-01Count the embedded emissions of Annex VIII input materials (precursors) when determining the embedded emissions of the goods.Operators and authorised CBAM declarants calculating embedded emissions · BusinessesRequirementCALC-02Apply the complex-goods calculation counting precursors from both Annex I and the new Annex VIII, excluding those from exempted third countries.Operators of installations producing complex CBAM goods · BusinessesRequirementCALC-03For iron and steel, aluminium and combined metal goods, derive the precursor mass from the content of input goods in the finished product rather than from a directly measured mass.Operators of installations producing iron and steel, aluminium and combined metal goods · BusinessesRequirementCALC-04Treat ferrous waste and scrap, other than post-consumer scrap, as a precursor whose embedded emissions count towards the goods.Operators and declarants using ferrous scrap as an input material · BusinessesRequirementCALC-06Bear the mark-up added to default values when declaring downstream goods with complex supply chains.Importers and declarants of listed downstream goods using default values · BusinessesSimplificationANTI-01Refrain from practices whose purpose is to gain a benefit by unduly avoiding, wholly or partly, the CBAM financial liability.All actors in the CBAM supply chain · BusinessesRequirementANTI-02Refrain from artificially adjusting supply chains so that goods qualify for lower default values; doing so is circumvention.Importers, declarants and operators in CBAM supply chains · BusinessesRequirementANTI-03Monitor the CBAM's internal-market impact, warn importers, declarants, competent and customs authorities of high-risk goods/origin combinations, and legislate the conditions for using actual emissions for them.European Commission · GovernmentsRequirementFIN-01Provide a bank guarantee payable at first demand, sized on the certificates that would have to be surrendered, where the competent authority finds financial capacity is not demonstrated.Applicants and authorised CBAM declarants failing to demonstrate financial capacity · BusinessesRequirementFIN-03From 2028, satisfy the quarterly certificate-holding requirement using only certificates bought in the same year, so certificates carried over from earlier years no longer count.Authorised CBAM declarants · BusinessesRequirementFIN-04Pay the CBAM certificate price as fixed by the fallback rules for weeks with no auction or a single auction.Authorised CBAM declarants purchasing CBAM certificates · BusinessesRequirementFIN-06Have the documentation evidencing a carbon price paid in a third country certified by a person independent from the authorised CBAM declarant AS WELL AS from that country's authorities.Authorised CBAM declarants claiming a carbon price paid in a third country · BusinessesSimplificationFIN-08Apply the Commission's conversion rules when turning a carbon price paid abroad into a reduction in CBAM certificates, including the evidence of actual payment and any deduction of Paris Agreement Article 6 carbon credits.Authorised CBAM declarants claiming a carbon price paid in a third country · BusinessesRequirementDATA-01An operator may pass verified emissions and carbon-price information not only to an authorised CBAM declarant but to another operator, so verified data can move along the supply chain.Operators of installations in third countries registered in the CBAM registry · BusinessesEntitlementDATA-02An operator may limit what it hands the declarant to a summary of the registered information, and the declarant is entitled to rely on that summary to discharge its Article 8 verification obligation.Operators of third-country installations and the authorised CBAM declarants they supply · BusinessesEntitlementDATA-03Remain responsible for surrendering the correct number of CBAM certificates even where the declaration was built on information disclosed by the operator.Authorised CBAM declarants relying on operator-disclosed information · BusinessesRequirementDATA-04Ensure that the conditions laid down for using actual emissions are met for the relevant combinations of goods and origins.Operators of installations registered in the CBAM registry · BusinessesRequirementDATA-05A third-country operator may have its installation registered in the CBAM registry not only to support actual-emissions verification but to establish the carbon price it has paid at home.Operators of installations located in third countries · BusinessesEntitlementCUST-01Communicate import data to the Commission automatically, now including bills of discharge, re-export declarations and equivalent customs documentation, and the importer's identity where there is no EORI number.Customs authorities of the Member States · GovernmentsRequirementCUST-02Accept that the CBAM account number entered in the customs declaration fixes which authorised CBAM declarant assumes the obligations for that consignment.Authorised CBAM declarants and importers · BusinessesRequirementCUST-04Apply the material and chemical compositions that the Commission fixes by implementing act for Annex I goods.Importers and authorised CBAM declarants of Annex I goods · BusinessesRequirementGOV-01Base the 2027 assessment due by 30 April 2027 on import data for the goods in both the existing and the newly extended Annex I.European Commission · GovernmentsRequirementGOV-02Report to Parliament and Council before 1 January 2028 and biennially thereafter on CBAM's operation, covering carbon leakage, internal-market and price effects, governance, circumvention practices, penalties and per-country emission intensity.European Commission · GovernmentsRequirementGOV-03State the material composition of each downstream good in the verification report.Accredited verifiers preparing CBAM verification reports · BusinessesRequirementGOV-04Set out in the verification report the quantities of each type of goods produced, the quantification of the installation's direct emissions, how those emissions are attributed across goods, and the energy and emissions flows not associated with those goods.Accredited verifiers preparing CBAM verification reports · BusinessesSimplificationCBAMB-SCP-07Declare embedded emissions and surrender certificates for goods added to the existing 'Iron and steel' table -- agglomerated iron ore, stranded wire and cables, unplated welded grill and netting, springs, enamelled and other household articles, and other cast articles of iron or steel.Importers and authorised CBAM declarants of the newly listed iron and steel goods · BusinessesRequirementCBAMB-VER-02Use a verifier accredited by a Member State national accreditation body, there being no route to recognition of a third-country accreditation body.Authorised CBAM declarants and third-country operators procuring verification · GovernmentsSimplificationCBAMB-DECL-07Report, in the standard declaration format, the detail supporting each total -- per installation and per country of origin -- including the carbon price paid and the default carbon price for the purposes of Art. 9(4).Authorised CBAM declarants · BusinessesRequirementCBAMB-ANTI-05Designate, by implementing act, the goods or goods/origin combinations for which traceability evidence must accompany the declaration, and the type of evidence required.European Commission · GovernmentsRequirementCBAMB-CUST-05Communicate customs information at the scope, periodicity, timing and by the means the implementing acts prescribe, for the competent-authority flow under Art. 25(3) as well as the customs flow under Art. 25(2).Member State customs authorities and competent authorities · GovernmentsRequirement
11 measures
Power and heat
ELEC-01Accept default values for imported electricity that reflect fossil generation only, regardless of the exporting country's actual generation mix.Importers and authorised CBAM declarants of electricity · BusinessesSimplificationELEC-02Take the alternative default value from the CO2 emission factor, rather than from the emission factor for electricity, when demonstrating that the exporting area's electricity is cleaner than the applicable default.Importers and authorised CBAM declarants of electricity from lower-carbon third countries · BusinessesSimplificationELEC-03Accept the standard default value for indirect emissions where the exporting country's actual electricity mix is cleaner than that default.Importers of goods with indirect emissions from lower-carbon third countries · BusinessesSimplificationELEC-04Hold a power purchase agreement directly with the third-country electricity producer, with no intermediary in the chain, in order to claim actual emissions.Importers and authorised CBAM declarants of electricity claiming actual emissions · BusinessesSimplificationELEC-05Demonstrate that the generating installation is directly connected to the Union transmission system, or that no physical network congestion existed at the time of export, in order to claim actual emissions for imported electricity.Importers and authorised CBAM declarants of electricity claiming actual emissions · BusinessesSimplificationELEC-06Firmly nominate the claimed electricity to allocated interconnection capacity across origin, destination and transit, matching production within the same hour, and forgo the claim where capacity is allocated implicitly.Importers and authorised CBAM declarants of electricity claiming actual emissions · BusinessesRequirementELEC-07Conclude, and then honour, a Memorandum of Understanding setting the timeline for the Art. 2(7) exemption and for putting an EU ETS-equivalent carbon price on electricity generation.Third countries seeking electricity market coupling with the Union, and the Commission · GovernmentsRequirementELEC-08Assess third-country listing for the electricity exemption against the Memorandum of Understanding timeline as well as the paragraph 7 conditions.European Commission · GovernmentsRequirementCBAMB-ELEC-09Use, as the emission factor for electricity, the weighted average CO2 intensity of all electricity produced in the geographic area, in place of a factor representing the emission intensity of the electricity consumed in producing the goods.Importers and authorised CBAM declarants of electricity and of goods carrying embedded indirect emissions · BusinessesRequirementCBAMB-ELEC-10Hold a power purchase agreement that involves the physical delivery of electricity, not merely a direct contractual purchase, in order to claim actual embedded emissions for imported electricity.Importers and authorised CBAM declarants of electricity claiming actual emissions · BusinessesRequirementCBAMB-SCP-08A third country or territory may be added to or removed from the Annex III exemption lists by delegated act, including as a consequence of CBAM incorporation into the EEA Agreement, and under urgency where imperative grounds require it.European Commission; importers of goods originating in third countries listed in Annex III · GovernmentsRequirement
8 measures
No sector named — applies by size or activity
DECL-04Identify in the authorisation application, by EORI or national identification number, every person on whose behalf the applicant acts.Applicants for authorised CBAM declarant status acting on behalf of others · BusinessesRequirementANTI-04Adopt the high-risk delegated acts within three months of finding sufficient evidence of a high risk of abusive practices.European Commission · GovernmentsRequirementFIN-02Leave the guarantee in place until after 30 September of the second surrender year, and for longer where the competent authority justifies an extension.Authorised CBAM declarants that have provided an Art. 17(5a) guarantee · BusinessesRequirementFIN-05Repurchase the excess CBAM certificates through the common central platform on behalf of the Member State where the authorised CBAM declarant is established.European Commission · GovernmentsSimplificationFIN-07Find a certifying person meeting the independence test without the benefit of an express route through national accreditation.Authorised CBAM declarants claiming a carbon price paid in a third country · BusinessesSimplificationCUST-03Verify, on a competent authority's request, the correctness or accuracy of communicated customs information.Customs authorities and the Commission · GovernmentsRequirementVER-01Follow the verification procedures the Commission specifies by delegated act.Accredited verifiers of embedded emissions · BusinessesRequirementGOV-05Publish the CBAM certificate price on the first working day of the following calendar week.European Commission · GovernmentsRequirement
Audit view
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