The EU CBAM downstream extension, proposed by the Commission on 17 December 2025, would expand the Carbon Border Adjustment Mechanism from 6 product categories to approximately 186 downstream product types. For UK manufacturers exporting processed metals and fabricated products to the EU, this is a significant escalation of CBAM exposure.
What Is the Downstream Extension?
The current CBAM covers primary products: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The proposed downstream extension would add processed and fabricated products derived from these primary goods, including:
- Processed steel: Screws, bolts, nuts, tubes, pipes, wire, wire products, springs, chains, metal structures
- Processed aluminium: Foil, tubes, fittings, structures, casks, containers
- Other metals: Certain tin, copper, nickel, and zinc products
- Metal furniture and fixtures
Current Status
The Commission’s proposal is currently in trilogue (negotiations between Commission, Parliament, and Council). Key debate points include:
- Scope: whether all 186 products are included or a reduced list
- Timeline: proposed application from 2028 but may be delayed
- Calculation methodology: whether to use simplified approaches for complex manufactured goods
- Anti-circumvention measures: preventing rerouting through non-CBAM countries
Impact on UK Manufacturers
UK manufacturers currently exporting products outside the 6 primary CBAM categories may assume they are unaffected. If the downstream extension is adopted, this changes significantly:
- Steel fabricators, metal product manufacturers, and aluminium processors would need installation-level embedded emissions data
- Calculation methodology for complex products is more challenging than primary materials
- EU customers would require verified emissions data or face punitive default values
- Price competitiveness against EU-domestic producers would be affected
What UK Exporters Should Do Now
- Audit your product portfolio: Identify which products fall within the proposed 186 CN codes
- Begin emissions measurement: Start collecting installation-level energy and process emissions data
- Engage your EU customers: Understand their CBAM data requirements and timeline expectations
- Monitor trilogue progress: The final scope and timeline may differ from the Commission proposal
- Use our CBAM Compass tool for an initial exposure assessment
RSustain Advisory
RSustain provides CBAM embedded emissions advisory for UK exporters, including product CN code mapping, installation-level emissions calculation, and EU customer reporting support. Book a free scoping call.
RSustain UK provides advisory services only.