The latter occurs if EU producers of downstream goods move production abroad to avoid increased carbon costs, or if EU buyers switch to imports from third countries with weaker climate policies. Additional anti-circumvention measures would target practices aiming to avoid the CBAM financial obligation, without due cause or economic justification.
The consultation aims to gather the opinions of all stakeholders on the policy design of CBAM’s potential downstream scope extension, anti-circumvention measures, and rules for electricity, as well as on their potential social, economic, environmental, and administrative impacts.
The main target audiences are EU-based and non-EU stakeholders, namely:
- companies active in the production, trading and warehousing of CBAM basic goods (including electricity) and downstream goods;
- associations of producers of CBAM basic goods (including electricity) and downstream goods;
- non-governmental organisations;
- academic institutions – in line with the Commission’s better regulation policy to develop initiatives informed by the best available knowledge, we particularly invite researchers and academic organisations to submit relevant published and pre-print scientific research, analyses and data;
- public authorities, including customs authorities; and
- trade unions.
You can share your feedback on this initiative until 26 August 2025 here: Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures
