Carbon Border Adjustment Mechanism: extension of its scope to downstream goods and anti-circumvention measures

Stegra fully supports the European Commissions ambition with the Carbon Border Adjustment Mechanism (CBAM), which targets the embedded carbon emissions of products imported into the EU in specific sectors that are within the scope of the EU ETS and the most at risk of carbon leakage.

STX Group (STX) welcomes the introduction of the Carbon Border Adjustment Mechanism and appreciates the opportunity to provide feedback on the Commissions initiative to assess possible scope extensions, anti circumvention measures, and clarify the rules on indirect emissions. Our comments refer mainly to the rules for calculation of emissions for electricity. Please see the attached PDF for our full feedback.

Member of European Chemical Industry Council CEFIC Warsaw, 26.08.2025 Polish Chamber of Chemical Industry submission to the public consultation on Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions As the national organization representing the chemical industry in Poland, the Polish Chamber of Chemical Industry (PIPC) submits the following views to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We support the overall objective of CBAM as a tool to put a fair price on the carbon emitted during the production of carbon-intensive goods imported into the EU, to avoid carbon leakage, and to encourage cleaner industrial production in non-EU countries.

We are a consulting company specialised in commodity trading advisory with a focus on power markets. The uncertainties created by the absence of guidance are putting a toll on trading in general making impossible, i.e to correctly price cross border capacities between any EU country and a non-EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Republic of South Africas (SA) Department of Trade, Industry and Competition (the dtic) would like to thank the European Commission for the opportunity to comment on the EUs Carbon Border Adjustment Mechanism (CBAM) downstream extension, additional anticircumvention measures and rules for the electricity sector: legislative proposal to amend the CBAM Regulation (EU 2023/956).

Danish Industry August 26th 2025 CBAM – downstream expansion On behalf of Danish Industry, we thank you for the opportunity to provide input to the consultation regarding conditions and procedures related to the status of CBAM scope expansion.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Downstream extension of CBAM rules shall also cover HS group 8482 (ball and roller bearings). In most cases, their components are purely manufactered from steel. Such an extension is really a must if we want to keep the manufacturing processes within EU, to serve at least our regional market. Internal costs optimizations are not enough here to recover competitiveness against Asian suppliers.

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry, would like to use this opportunity to raise its key recommendations. While CBAM can play a significant role in advancing environmental objectives, its implementation must carefully address potential risks, particularly negative trade impacts for both exports and imports of businesses operating in…

The current efforts of the EU to decarbonize the steel industry and at the same time remain internationally competitive require mandatory regulatory compensation measures in order to maintain pressure on non-EU countries and industries to also adapt these targets if they also want to serve the European market.

August 26, 2025 Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions The Brazilian National Confederation of Industry (CNI) welcomes the consultation being undertaken by the European Commission regarding the possible extension of CBAM to downstream products, as well as anti-circumvention measures, prior to proposing any regulations on these matters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The finalisation of ongoing CBAM legislative acts should take precedence over any scope extension, bringing the existing regulation to an operationally stable state that is clear and practical for all stakeholders.

The Carbon Border Adjustment Mechanism (CBAM) is an important instrument for creating fair competition and offsetting the sustainability costs arising from the abolition of the ETS. At the same time, an adjustment and the associated closure of loopholes is essential to guarantee fair competition and prevent the migration of CO2-intensive industries.

The Brazilian Aluminium Association (ABAL) appreciates the opportunity to contribute to the public consultation "Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions". Below we highlight the points we consider most relevant and on which we would like to suggest adjustments, in order to strengthen the sustainable objectives of the European CBAM: 1.

Trafigura Response August 2025 Introduction & Who We Are Trafigura is one of the world’s largest commodity trading and logistics companies, supplying metals and minerals, oil and petroleum products, and gas and power into the EU. The Group also owns a diverse European portfolio of assets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To limit the risk of delocalisation of manufacturing activities downstream the value chain, CBAM should also apply to additional intermediate and finished products. A CBAM that would lead to offshore assembly or finishing industrial activities would be an unacceptable threat to employment in industries and would be in conflict with the EU industrial strategy objectives such as the open strategic autonomy.

ePURE is the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, with renewable ethanol classified under NACE 20.14 - Manufacture of other organic basic chemicals and 20.51 - the Manufacture of liquid biofuels (20.51).

Nemo Link welcomes the opportunity to provide its views to the EC consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. The current EU CBAM legislation will lead to many unintended and negative consequences for electricity trade, notably for trading electricity between the EU and the UK.

Directorate_General for Taxation and Customs Union Unit C-5 (Economic Analysis and Taxation of Exempted Sectors) August 26, 2025 Call for evidence for an impact assessment - Comments submitted on behalf of NV Bekaert S.A. to the public consultation on the “Carbon Border Adjustment Mechanism – downstream extension, additional anti-circumvention measures and rules for the electricity sector” Introduction 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. It is important to include new products in the aluminium downstream chain, but it is also crucial to look upstream and consider relevant steps of production emissions that are currently not covered by the CBAM, such as the alumina refinery and emissions related to electricity consumption. 2.

Filed in Portuguese · English published by the European Commission

1. CBAM should not be expanded for downstream goods without technical criterion. We recommend that the possible inclusion of downstream goods in the CBAM be preceded by specific analyses of Technical Capability of Quantification at non-EU origins ", respecting different development realities.

Filed in Portuguese · English published by the European Commission

In the context of the public consultation on the extension of the scope of the Carbon Border Adjustment Mechanism (CBAM) to downstream products, the European Tyre Industry (ETRMA) would like to share its key recommendations and policy considerations on behalf of its members. Tyre manufacturing is energy intensive. It enables Europes economy and society.

Extending CBAM to downstream products would level the playing field by ensuring that cars imported from abroad follow the same regime as EU-made ones by paying a price on the carbon. Granting such a level playing field between vehicles produced in Europe versus those produced outside of Europe would reinforce the competitiveness of the European car industry.

RECOGNITION OF THE SOUTH AFRICAN CARBON TAX AS AN EFFECTIVE CARBON PRICE PAID UNDER EUROPEAN UNION (EU) CARBON BORDER ADJUSTMENT MECHANISM (CBAM) 1 INTRODUCTION The Minerals Council South Africa (Minerals Council) serves as a prominent industry association, representing mining companies that collectively contribute approximately 90% of South Africa’s mineral production by value.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the European Commissions initiative to expand the Carbon Border Adjustment Mechanism (CBAM) scope to downstream products. Without this, sectors such as melamine remain exposed to carbon leakage and risk losing competitiveness. European melamine producers face increasing pressure from cheaper, high-emission melamine imports, particularly from countries with weaker climate policies.

The Carbon Border Adjustment Mechanism (CBAM) can only achieve its objectives if reported emissions are accurate, fair, and resistant to circumvention. We see three key challenges: (1) reliance on facility-level averages instead of product-level reporting, (2) the lack of clear rules for traders and distributors including origin verification, (3) the need to account for supply chain variability in downstream…

The European Cylinder Makers Association supports the inclusion of CN codes 7311 00 Containers for compressed or liquefied gas, of iron or steel and 7613 00 00 Aluminium containers for compressed or liquefied gas into Regulation 2023/956.

EIGA welcomes the Commissions commitment to improving the Carbon Border Adjustment Mechanism (CBAM) and the opportunity to provide input. Downstream products A CBAM-related issue arises because hydrogen is a CBAM good, whilst many of its derivatives, and precursors from which hydrogen can be recovered, are not.

Foundation BFPE for Responsible Society (BFPE) welcomes the opportunity to respond to the European Commission's public consultation on the Carbon Border Adjustment Mechanism (CBAM), particularly regarding the rules for the electricity sector.

The CBAM is the EUs flagship initiative to decarbonise European industry by integrating carbon costs into production while avoiding carbon leakage. Yet, several products central to Europes industrial value chains remain outside its scope. EU producers could bear the costs of carbon pricing, while foreign competitors circumvent them by exporting carbon-intensive goods further down the value chain.

Feedback on the Extension of the Carbon Border Adjustment Mechanism (CBAM) to Downstream Products Batteries A dedicated study has been conducted on the battery sector with a particular focus on the competitiveness of second-life batteries. The findings, described in detail in the attached executive summary, show that the potential impact of CBAM on this sector is significant.

CONTRIBUTION CBAM – MACF MECANISME D’AJUSTEMENT DU CARBONE AUX FRONTIERES 26 AOUT 2025 1 DETAIL DE LA CONTRIBUTION 1. CALCUL DE L’IMPACT DU MACF SUR 9 ÉQUIPEMENTS DU GÉNIE CLIMATIQUE 2. POSITION D’UNICLIMA POUR UNE EXTENSION DU DISPOSITIF MACF AUX ÉQUIPEMENTS DU GENIE CLIMATIQUE COÛT DU CARBONE SUPPLÉMENTAIRE LIÉ AU CBAM PAR ÉQUIPEMENT 3. ANNEXES 2 1.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Expanding CBAM to Cover Nickel, Cobalt and Lithium Intermediates and Downstream Products Introduction The EUs Carbon Border Adjustment Mechanism (CBAM) is a cornerstone of Europes climate and industrial strategy. Yet, its current scope does not sufficiently cover key raw materials and intermediates critical to the clean energy transition.

European Commission Sent via the Have your say Portal Reykjavík, August 26th 2025 Regarding: Carbon Border Adjustment Mechanism – downstream extensions, additional anti-circumvention measures and rules for the electricity sector The Federation of Icelandic Industries (hereafter ,,the Federation“) welcomes the oppurtunity to provide feedback on call for evidence for an impact assessment regarding the Carbon Border…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SUEZ welcomes the Commissions consultation on the upcoming revision of the Carbon Border Adjustment Mechanism (CBAM). The CBAM is a necessary instrument to protect the European industry and support its decarbonization efforts. However, its current scope still leaves room for improvement, as it enables loopholes that could undermine its effectiveness.

1. Indirect emissions: the missing piece in CBAM Excluding indirect emissions leaves CBAM incomplete and undermines its environmental integrity. This is especially critical for aluminium and steel, where indirect emissions account for up to 95% of the total footprint.

AUGUST 2025 Accompanying paper to the consultation on the Carbon Border Adjustment Mechanism – downstream extension, additional anti-circumvention measures and rules for the electricity sector The flat glass sector is an EU ETS sector exposed to carbon leakage. It is also a hard-to-abate industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

August 2025 ACEA COMMENTS CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT: CBAM DOWNSTREAM EXTENSION AND RULES FOR THE ELECTRICITY SECTOR CBAM will assist ACEA (European Automobile Manufacturers Association) members in reaching climate neutrality commitments and is a necessary complimentary instrument to allow for increased ambition in the ETS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ARGE - The European Federation of Locks and Building Hardware Manufacturers welcomes the opportunity to provide feedback in response to this call for evidence. The Federation represents around 250 companies in 15 European countries (EU, Switzerland and UK). Most of these companies are privately owned, many of them being medium-sized enterprises. Some 50,000 employees generate annual sales of more than 10 billion.

26 août 2025 Mécanisme d'ajustement carbone aux frontières (MACF) – Extension en aval, anti-contournement et règles sur les émissions d'électricité Commentaires sur l'appel à contributions (1er juillet 2025 - 26 août 2025) UNIQ – Union Nationale des Industries de la Quincaillerie Déclaration clé Pour la grande majorité des fabricants français de serrures et de quincaillerie de bâtiment (produits relevant des codes…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Lightsource bp welcomes the opportunity to engage with the European Commission (EC) and respond to this consultation on the Carbon Border Adjustment Mechanism downstream extension. The attached position paper sets out our views, detailed considerations, and policy recommendations for the design and implementation of any downstream extension.

EDF’s position paper on the Carbon Border Adjustment Mechanism (CBAM) Feedback to the European Commission The EU’s Carbon Border Adjustment Mechanism (CBAM) is set to be implemented in the coming months (beginning of 2026). The CBAM represents a key pillar of the EU’s climate ambition, aiming to reduce carbon leakage, support a more sustainable European industrial base, and ensure fair carbon pricing on imports.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The VDMA represents 3600 German and European mechanical and plant engineering companies. The industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany.

EIFI, the European Industrial Fasteners Institute, is the recognized non-profit making organization registered under Belgian law, representing the European Fasteners Manufacturing Industry (bolts, screws, washers, nuts, rivets, other industrial fasteners of both ferrous and non-ferrous metals and other mechanical industrial fasteners) and its Supply Chain.

Eurolysine contribution to CBAM consultation – August 2025 1. Introduction Eurolysine 1, subsidiary of the Avril 2 Group, is the main producer of amino acids 3 established in the European Union, exclusively by fermentation. Amino acids are the main building block for proteins.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

National Grid welcomes the opportunity to provide its views to the EC consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. The current EU CBAM legislation will lead to many unintended and negative consequences for electricity trade, notably for trading electricity between the EU and the UK.

Farm Europe welcomes the European Commissions efforts to reinforce anti-circumvention measures linked to Regulation (EU) 2023/956 (CBAM) and prevent fraud. While CBAM is a useful tool to establish a market level-playing field and prevent carbon leakage, fraud risks seriously compromising the EU's objectives on decarbonisation and climate change, and distort calculations of the EU's sustainable transition targets.

Ibec Submission to the European Commission Consultation on Carbon Border Adjustment Mechanism (CBAM) downstream extension, anticircumvention and rules on electricity emissions 26 August 2025 1 Ibec, Ireland’s largest business and employers’ representative organisation, welcomes the opportunity to respond to the European Commission’s consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The carbon border adjustment mechanism (CBAM) is one of the building blocks negotiated between 2021 and 2023 under the last EU cycle. Its implementation aims at staying the course with the broad policy toolbox and objectives put forward in the past mandate, as stated by the newly elected Commission, especially in combination with the revised European Emissions Trading System (EU ETS).

CBAM in its current form is putting EU steel value chains at a competitive disadvantage. The EU cannot afford to implement a dysfunctional system that undermines its own industrial base. The well recognised 3 main loopholes of CBAM must be adressed before the start of the CBAM definitive phase by: 1) extending the CBAM scope to steel intensive downstream products (see priority list in attached document) 2)…

Notat 26. august 2025 J.nr. 2022 - 13708 Danish response to the European Commission’s consultation Call for Evidence for an Impact Assessment regarding potential amendments to the CBAM regulation including downstream scope extension, additional anti-circumvention measures and rules for the electricity sector Denmark welcomes the efforts of the Commission as it pertains to this public consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Foundry Association (BDG) represents Germanys ferrous and non-ferrous foundries. The German Foundry Industry does provide around 70,000 jobs with a turnover of about 12 billion euros and is an indispensable supplier for the automotive and mechanical engineering industry and enabler for the transformation.

The Carbon Border Adjustment Mechanism (CBAM) was agreed in 2023 and the trading of CBAM certificates is about to start on January 1st 2026. Omnibus I package simplified the participation requirements in 2025 by limiting the scope of the CBAM to larger imports.

Including downstream products, particularly motor vehicles, in CBAM would meaningful contribute to the goals of reducing carbon emissions and mitigating carbon leakage. Based on commissioned modeling research, including downstream products in CBAM, particularly motor vehicles, would mitigate carbon leakage and result in a global decrease in carbon emissions whereas excluding motor vehicles would result in an…

BASF welcomes the opportunity to contribute to the public consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. BASF supports the goal of a climate-neutral Europe by 2050 and is actively committed to climate-neutral production.

SolarPower Europe, the EU-level solar and battery energy storage industry association representing close to 320 members across the solar value chain, supports the Commissions objectives to reduce carbon leakage, ensure fair competition, and align climate policy with industrial resilience.

Please find attached the position of the German Association of the Automotive Industry (VDA). For the time being, the German automotive industry clearly rejects an extension of the CO2 border adjustment mechanism to downstream product groups due to the ques-tionable climate policy benefit, the risk of additional trade barriers, and the high com-plexity.

The Federation of the European Sporting Goods Industry (FESI) welcomes the opportunity to provide feedback on the consultation regarding a potential expansion of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. FESI supports the Commission's objective to address carbon leakage and accelerate the transition to a low-carbon economy.

Opinion Submission on the Public Consultation to Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions Hyundai Motor Group is an established European motor vehicle producer with significant manufacturing footprint in the EU, and with industrial ecosystem extending to Hyundai Steel, an exporting producer to the EU market, and Tier 1 supplier.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Euromines expresses its support for first a full coverage of downstream goods and introducing an export solution to evaluate and ensure the effectiveness of CBAM as a carbon leakage tool before extending the mechanism to other energy-intensive sectors.

CBAM should recognise permanent carbon removals The EUs Carbon Border Adjustment Mechanism (CBAM) incentivises climate action beyond the EUs borders, but it currently does not cover carbon removals. The CBAM Regulation must recognise carbon removals to: Help incentivise other countries to scale up their carbon removal efforts which are critical to reach EU climate goals; Ensure a level playing field between carbon…

1. Downstream Scope Extension Should CBAM apply to more products? What would the impact be? While we recognize that the proposed extension may contribute to a more level playing field and support efforts to reduce CO emissions, it appears to be primarily targeted at steel and metals. In the context of offshore wind, the most significant impact would concern foundation structures.

European Commission DG TAXUD.C.5 Brussels, 26 August 2025 EPF Feedback on CBAM Extension and Anti-Circumvention Measures The European Panel Federation (EPF), representing the wood-based panels industry in Europe, welcomes the opportunity to comment on the proposed extension of CBAM to downstream products and on measures to prevent circumvention.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Representing manufacturers of European heating systems, the European Heating Industry (EHI) welcomes the opportunity to share its views on the EU Commissions proposal to extend the Carbon Border Adjustment Mechanism (CBAM) to downstream goods.

Business for CBAM Coalition Position on anti-circumvention measures to strengthen CBAM In the Steel and Metals Action Plan, the Commission announced it will present an anti-circumvention strategy to strengthen the Carbon Border Adjustment Mechanism (CBAM) in Q4 2025.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The CBAM transitional phase ends on 31 December 2025. From then, the definitive regime begins, phasing out free ETS allowances and requiring CBAM certificates for goods listed in Annex I. CBAM is supposed to complete the EU-ETS and create a level playing field for European industries by applying the same carbon price on imported goods as if they were produced in the EU. But for now, CBAM is incomplete.

CNA believes it is essential that the revision of the CBAM includes a mix of measures necessary to strengthen the competitiveness of Italian and European mechanical engineering companies, a strategic sector for the development of our industrial system that deserves to be protected and safeguarded for its significant contribution to growth and employment.

Brazil's comments on the public consultation "Carbon Border Adjustment Mechanism – downstream extension, additional anti-circumvention measures and rules for the electricity sector" Brussels, 26 August 2025 The Government of Brazil expresses its appreciation for the opportunity to submit comments on the European Union`s public consultation regarding its proposed Carbon Border Adjustment Mechanism (CBAM)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Given the unique nature of electricity as a traded good, it is of utmost importance that the conditions and implementing acts governing the application of the Carbon Border Adjustment Mechanism (CBAM) to electricity are fully aligned with the fundamental principles of electricity markets.

ANIMA Confindustria, the Italian federation of mechanical manufacturers, is generally supportive of extending the CBAM scope to downstream products. However, several concerns remain. First, ANIMA strongly advocates for a sector-specific rather than a general approach to determining which downstream products should fall under the CBAM scope, given that some products are part of multiple value chains.

We welcome the opportunity offered by the European Commission to provide feedback on the public consultation on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emission.

Joint position on EU-UK electricity exchanges Feedback on the Extension of the scope of the Carbon Border Adjustment Mechanism to downstream products and anticircumvention measures – 08.2025 Unlocking the full potential of current and future electrical interconnections across the Channel and in the North Seas is vital to achieving the net zero objectives for both sides The EU and the UK share similar commitments and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide feedback on the European Commission's consultation regarding the extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. As the principal European organisation representing the retail and wholesale sector, with a large part of the membership being deeply involved in global supply chains and committed to supporting the EU's climate objectives, we…

TOYOTA MOTOR EUROPE Ref. Ares(2025)6890631 - 26/08/2025 TOYOTA’S CONTRIBUTION TO THE CONSULTATION ON THE EXTENSION OF THE CARBON BORDER ADJUSTMENT MECHANISM (CBAM) TO DOWNSTREAM PRODUCTS Toyota is a significant contributor to the European economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

JP Elektroprivreda HZ HB d.d. Mostar, a vertically integrated electricity utility operating in Bosnia and Herzegovina, welcomes the opportunity to provide input on the European Commissions initiative to amend the Carbon Border Adjustment Mechanism (CBAM) Regulation.

Eurovent is the voice of the European Heating, Ventilation, Air Conditioning and Refrigeration (HVACR) industry. This paper outlines Eurovents position on the extension of CBAM to downstream products, insofar as it may include HVACR equipment.

Joint position on EU-UK electricity exchanges Feedback on the Extension of the scope of the Carbon Border Adjustment Mechanism to downstream products and anticircumvention measures – 08.2025 Unlocking the full potential of current and future electrical interconnections across the Channel and in the North Seas is vital to achieving the net zero objectives for both sides The EU and the UK share similar commitments and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Joint position on EU-UK electricity exchanges Feedback on the Extension of the scope of the Carbon Border Adjustment Mechanism to downstream products and anticircumvention measures – 08.2025 Unlocking the full potential of current and future electrical interconnections across the Channel and in the North Seas is vital to achieving the net zero objectives for both sides The EU and the UK share similar commitments and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a South African manufacturing steel company which exports certain steel products to the EU, Scaw strongly advocates against the extension or expansion of the CBAM to further downstream products due to our view that unilateral carbon border adjustment mechanisms are not efficient mechanisms to combat climate change.

Directorate-General for Taxation and Customs Union European Commission 1049 Brussels Belgium [email removed] Eleclink Limited 4 Kingdom Street London W2 6BD BY EMAIL ONLY Tuesday, 26 August 2025 Dear Sir/Madam, RE: Carbon Border Adjustment Mechanism – downstream extension, additional anticircumvention measures and rules for the electricity sector Eleclink Limited (“Eleclink”) welcomes the opportunity to respond to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

INTERFER Edelstahl Handelsgesellschaft mbH is an EU-based steel trading company with almost 40 years of experience. Due to our product portfolio, which includes steel bars, wire rods, flat steels and raw materials for steel production, we are directly affected by CBAM. We are committed to the climate objectives of the European Union. The decarbonisation of the steel industry is essential to achieve these goals.

We welcome the opportunity to contribute to the European Commissions consultation on the CBAM for electricity. Our response highlights key concerns associated with the planned implementation of implicit market coupling in the Energy Community as well as the expected impact of CBAM on power prices, market efficiency and long-term regulatory certainty.

Brussels, August 2025 Ref. Ares(2025)6889336 - 26/08/2025 European Shipowners | ECSA response to the consultation on the extension of the Carbon Border Adjustment Mechanism (CBAM) scope European Shipowners | ECSA (ES|ECSA) welcomes the opportunity to respond to the consultation on the extension of the scope of the Carbon Border Adjustment Mechanism (CBAM).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Recycling Industries Confederation (EuRIC) calls for a robust and future-oriented implementation of CBAM that closes current loopholes, supports genuinely low-carbon production methods, and ensures fair competition for recycled materials and EU industries. Please find our detailed feedback attached.

INVITO A PRESENTARE CONTRIBUTI PER UNA VALUTAZIONE D'IMPATTO DELLA COMMISSIONE EUROPEA Meccanismo di adeguamento del carbonio alle frontiere – estensione a valle, ulteriori misure antielusione e norme per il settore dell'energia elettrica 26 agosto 2025 1 Con la consultazione “Meccanismo di adeguamento del carbonio alle frontiere – estensione a valle, ulteriori misure antielusione e norme per il settore dell'energia…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Furniture Industries Confederation (EFIC) welcomes the opportunity to provide comments to the European Commissions public consultation on the extension of the scope of the CBAM to downstream products and anti circumvention measures. The European CO2 Border Adjustment Mechanism (CBAM) was introduced to protect the competitiveness of European industry and prevent carbon leakage.

Siemens Healthineers is a leading provider of medical technology, principally active in the areas of imaging, diagnostics, cancer care and minimally invasive therapies augmented by digital technology and artificial intelligence.

Ford Otosan as an automotive company operating manufacturing sites in both Türkiye and Europe enabling strategic regional production suggests the EU Commission to ensure a fair, effective, and environmentally sound implementation of CBAM without undermining global industrial partnerships or disrupting integrated supply chains.

Extending scope of CBAM from the view of power producers Energy sector is at the forefront of the EU decarbonization efforts, which is clear not only from so far reported emission reductions but also from the short-term future emission trajectories. That is why power producers cannot unconditionally support the extension of the CBAM scope downstream. If the energy transformation is about deploying low carbon (e.g.

We appreciate the opportunity to provide feedback on the ongoing consultation regarding the Carbon Border Adjustment Mechanism (CBAM) and its potential extension to downstream products. We are a sensor and automation specialist company headquartered in Europe and we import key raw materials such as iron, steel, and aluminium from non-EU countries, and sell our products globally.

The Bundesverband Großhandel, Foreign Trade and Services (BGA) has long been critical of the CBAM and strongly opposes its planned extension to downstream products, the introduction of additional circumvention measures and the inclusion of electricity emissions in its scope.

Filed in German · English published by the European Commission

Contribution à la consultation publique sur l’extension du mécanisme d’ajustement carbone aux frontières (MACF) A propos du groupe Humens Le groupe Humens est une ETI française produisant principalement du carbonate et du bicarbonate de sodium, depuis plus de 170 années.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Comission Team, We would like to provide feedback on Annex IV, points 5 and 6 of Regulation (EU) 2023/956. These provisions allow actual indirect emissions to be used if a company can demonstrate either a direct physical link or a power purchase agreement (PPA) with a renewable electricity producer. Furthermore, Annex IV, point 1(f) defines a PPA as the direct purchase of electricity from a producer.

DHL Group welcomes the opportunity to comment on the Commission call for evidence on a potential CBAM extension. While we fully support the environmental objectives of the CBAM, we strongly believe that legal liability should rest with entities that produce and/or are able to verify the emissions during the production process not with logistics intermediaries who lack both oversight and authority yet are currently…

The Federation of Norwegian Industries supports the introduction of CBAM in the EU and Norway. The following feedback relates to the possible expansion of the scope of CBAM: Materials that compete with current CBAM products should be included in CBAM: Expanding scope of CBAM to other products can be considered when the existing CBAM framework has been improved and is documented to provide solid carbon leakage…

In response to this call for evidence we provide evidence and policy recommendations in relation to the following question: How can the EU's carbon border adjustment mechanism be redesigned to help with its goals for net zero? In addressing this question, we focus on the potential improvements of the border adjustment mechanism that should support decarbonisation policies and mitigate the risk of carbon leakage.

The Association of Producers of Paps (SPP) has been active on the Polish market for the production of building materials since 1997, bringing together companies producing bituminous paps, bituminous nails and bituminous masses The main raw material used for the production of bituminous paps and shakes is asphalt, obtained as one of the fractions of oil processing.

Filed in Polish · English published by the European Commission

We are Azareta S.L.U a company in the iron and steel sector active in the manufacture of several wire rod products (Wire Rod), intended as an intermediate or final product in the following sectors: industrial, automotive, agricultural, recycling of industrial and municipal waste, among others.

Filed in Spanish · English published by the European Commission

Please find attached ANIMEEs contribution to the public consultation on the Carbon Border Adjustment Mechanism (CBAM), focusing on downstream extension, anti-circumvention, and electricity emissions. We remain available for any further clarification or follow-up.

The Norwegian Confederation of Trade Unions (LO) and the Confederation of Norwegian Enterprise (NHO) welcomes the opportunity to contribute to the consultation on the proposed extension and revision of the Carbon Border Adjustment Mechanism (CBAM).

We appreciate the opportunity to contribute to this important policy discussion and remain committed to supporting the EUs climate objectives through fair, transparent, and effective mechanisms. As a manufacturer of aluminum and steel wheels operating outside the European Union, we respectfully submit the following recommendations regarding the proposed extension of the Carbon Border Adjustment Mechanism (CBAM) to…

This initiative aims to extend CBAM to some downstream products to reduce the risk of carbon leakage when downstream manufacturers relocate their production abroad. However, CBAM will increase both manufacturing costs and export costs for German and European companies. These costs can only be passed on to the consumer, resulting in a competitive disadvantage.

Conclusion: To ensure a fair, effective, and environmentally sound implementation of CBAM, the following actions are essential: TürkiyeEU Relations: Acknowledge Türkiyes unique position as a Customs Union partner committed to EU-aligned climate policy and national ETS development.

The Spanish Chamber of Commerce considers it necessary to review the application of the Carbon Border Adjustment Mechanism (CBAM), both for its refinement and for its possible extension. We believe that this mechanism should ensure regulatory clarity, proportionality in the obligations of economic operators and coherence with other EU climate policy instruments.

Filed in Spanish · English published by the European Commission

We strongly support the Commissions objectives to extend CBAM to downstream products, close anti-circumvention loopholes, and reform electricity-emissions accounting. We recommend adopting the E-ledgers carbon accounting method as the foundation for these reforms. The method provides auditable, product-specific, invoice-level tracking of embedded emissions across value chains.

Baker Hughes is a leading energy technology company that provides solutions for energy and industrial customers worldwide. We design, manufacture, and service transformative technologies to help take energy forward making it safer, cleaner, and more efficient for the people and the planet. While we operate globally, Europe is a key market and corporate home for Baker Hughes.

The current CBAM legislation, particularly concerning reporting obligations, poses a significant administrative burden when applied to the movement of metal racks (HS code 7326) used as returnable packaging. The European Commission's proposed solution, which suggests utilizing temporary customs operations as defined in the Union Customs Code for such products, is deeply problematic.

The Asociación de Trefiladores del Acero on behalf of our Associates (wire drawing, meshes and manufacturers of nails, tips and similar wire drawings), we respectfully submit this request for your consideration regarding the scope of products included in the Carbon Border Adjustment Mechanism (CBAM). In the attachment letter you will see our allegations.

The European Express Association (EEA) is pleased to provide its feedback to the consultation regarding the downstream extension, anti-circumvention and rules on electricity emissions in its attached position paper. The EEA is available to address any questions or requests for clarification via our Secretariat's functional email: [email removed].

CBAM implementation creates significant risks for Ukraines economy and industries. Even before the full-scale russian invasion, Ukraine was identified as one of the countries most exposed to CBAM. The war has dramatically worsened the situation, with massive destruction of industrial and energy infrastructure, limited export corridors, logistics costs three to five times higher than pre-war levels, and severe labor…

Carbon Market Watch urges the Commission to keep emission reductions at the top of their policy priorities. New downstream products shall be added only after a careful analysis assessing the global emission decrease the expansion could generate, and in no case expanding the product list should jeopardise the entry into force of the CBAM in 2026, alongside the phase-out of ETS free allocations.

The Carbon Border Adjustment Mechanism (CBAM) is a tool to support European climate objectives. However, in its current form, its implementation will generate significant administrative burdens and increase production costs for the European factories of several GIMELEC member manufacturers. Their competitiveness against non-European competitors not subject to the same constraints will therefore be weakened.

The batch galvanizing industry is an integral part of the steel value chain acting as a sub-contract provider of long-term corrosion protection for steel products that are used mainly in construction, renewable energy and transport infrastructure sectors.

EU Transparency Register: 05032108616-26 Ref. Ares(2025)6881974 26 August 2025 - 26/08/2025 Shell1 welcomes the opportunity to respond to the Commission’s Call for Evidence on the rules on electricity emissions under the Carbon Border Adjustment Mechanism (CBAM), such as concerns the rules on default values and the criteria for using actual electricity emissions for estimation purposes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Fossil carbon emissions are confirmed in any Google search to be the greatest driver of the worlds climate crisis, yet application of CBAM to textiles would unfairly promote fossil-based fibres (i.e. polyester and nylon) over natural fibres like cotton and wool. This is due to inequitable assessment of carbon emissions. For natural fibres, the impacts of fibre formation are fully counted (i.e.

The Czech steel sector calls for urgent and effective solutions to make CBAM effective and fit for purpose, incl. CBAM downstream extension and strong anti-circumvention measures. Attached please find our position paper containing justification and several solutions in this regard, including list of individual CN codes we need to be covered by CBAM.

Svemin expresses its support for first a full coverage of downstream goods and introducing an export solution to evaluate the effectiveness of CBAM as a carbon leakage tool before extending the mechanism to other energy-intensive sectors.

Dear Sir/Madam, I attach my paper examining the issues surrounding applying CBAM to power imports. I provide a critique as well as some practical solutions to enable the entire Pan-European power market to participate in the objectives of the CBAM regulation, yours faithfully ALAN RILEY

// Full feedback attached as PDF // Summary: An extension of the scope should be postponed until the original regulatory framework for the definitive phase has been fully established. It is almost impossible to evaluate an extension appropriately without a complete regulatory package (methodology, recognition of foreign regulations, standard and benchmark values, distribution cost plan, verification).

Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions Olimpia Splendid S.p.A. - Feedback on the Consultation (01 July 2025 - 26 August 2025) Olimpia Splendid S.p.A.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COMMENTS EU CBAM Regulation public consultation on downstream scope extension, anti-circumvention measures, and rules on electricity emissions. Nickel Institute Comments 26th August 2025 Introduction The Nickel Institute 1 takes note of the public stakeholder consultation on the EU CBAM regulation on downstream scope extension, anti-circumvention measures, and rules on electricity emissions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050.

40, rue Belliard I B – 1040 Brussels - 26/08/2025 T: [phone removed]Ref. I E:Ares(2025)6879768 [email removed] W: www.cirfs.org VAT Number: BE0451.888.158 CBAM Downstream expansion CIRFS is the representative body of Europe’s €12 billion MMF industry, covering approximately 70 percent of European production and sustaining around 20,000 jobs across 250 facilities throughout the Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We sincerely appreciate the opportunity provided to third-country industry associations and companies to express views in this consultation. We would also like to express our deep respect for the EUs leadership in implementing environmental regulations such as the CBAM, which drive global progress toward a sustainable society.

For the CBAM to promote renewable energy globally, companies must have clear, simple and robust guidance on reporting individual emissions based on contractual ownership of renewable energy. The European Commission (EC) should ensure CBAMs methodologies remain clear and adaptable in countries with different energy sectors.

EUROPEAN UNION OFFICE NON-PAPER Reflection paper on Carbon Border Adjustment Mechanism How to comply with European regulations aimed at protecting domestic steel production while addressing the specific needs and requirements of maintaining the competitiveness of the civil and military shipbuilding industry in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Effectively addressing carbon leakage is essential to maintaining industrial competitiveness while supporting Europes climate objectives. When CBAM enters its definitive phase on 1 January 2026, importers of covered goods will bear financial responsibility for embedded emissions, with payments beginning in 2027. As a first-of-its-kind instrument, CBAMs effectiveness remains uncertain.

TURKISH STEEL PRODUCERS ASSOCIATION Subject: CBAM: Public consultation on the extension of CBAM to downstream products Potential Impacts of the European Union's CBAM Expansion Approach on the Turkish Steel Sector As the Turkish Steel Producers Association (TÇÜD) and sector representatives, we are closely monitoring the European Union's (EU) initiative to expand the Carbon Border Adjustment Mechanism (CBAM).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European textile and clothing industry is committed in supporting the EUs climate neutrality objective for 2050. The goal of the Carbon Border Adjustment Mechanism (CBAM) is crucial in ensuring that the EUs climate policies are not undermined by carbon leakage, and that industries globally are held to similar environmental standards.

Feedback on CBAM Extension and Implementation Challenges of Endress+Hauser Group We appreciate the opportunity to provide feedback on the proposed extension of the Carbon Border Adjustment Mechanism (CBAM) and its associated implementation measures. As an EU importer actively preparing for CBAM compliance, we would like to highlight the following points based on our internal assessment:

Statement of the Korea Iron and Steel Association (KOSA) regarding European Carbon Border Adjustment Mechanism – downstream extension, additional anticircumvention measures and rules for the electricity sector 26 August, 2025 Korea Iron and Steel Association (KOSA) 15F, IT Venture Tower (East Wing), 135 Jungdae-ro, Songpa-gu, (78 Garak-dong), Seoul, 05717, Republic of Korea [phone removed] / [email removed], [email…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide input on the proposed extension of the Carbon Border Adjustment Mechanism (CBAM) and wish to reaffirm our full support for the EUs climate objectives and efforts to maintain a level playing field for domestic industry. As it stands, the current CBAM regime is highly ambitious and introduces a complex new compliance landscape for EU industry.

The European Unions Carbon Border Adjustment Mechanism (CBAM) is a critical tool to create a level playing field between domestic EU production and imports. Itis critical against global carbon leakage and in supporting the EUs climate ambitions.

I work in the steel and iron sector, and I would like to share observations on the European Commissions initiative to extend the scope of the Carbon Border Adjustment Mechanism (CBAM). 1. Downstream products: Extending CBAM to include steel-based downstream products will significantly affect global supply chains.

Ericsson welcomes the opportunity to contribute to the Call for Evidence on the potential extension of the EU CBAM. Ericssons view is that, from a competitiveness perspective, it is important that EU companies are competing on the same conditions as companies that export into EU. However, Ericsson also argues that advanced and complex downstream products should not be included in the future extension.

The current CBAM scope covers some aluminium and steel packaging products, but others are omitted, which creates loopholes and inefficiencies. This enables foreign companies to import semi-finished products and components (produced in countries where the aluminium and steel sector is often heavily subsidised) at more competitive conditions and thus circumvent the CBAM and the EU trade measures.

Anti-circumvention measures To ensure CBAM achieves its core objective preventing carbon leakage while maintaining fair competition the Regulation must comprehensively address circumvention risks. These include resource shuffling, unverifiable emissions claims, and regulatory loopholes that benefit importers over European producers.

We, N3 Engine Overhaul Services GmbH & Co. KG, are the European Competence Centre for the maintenance and repair of Rolls Royce engines of the Trent series. As a joint venture between Lufthansa Technik AG and Rolls-Royce plc, we are based in Arnstadt. Around 1100 staff on behalf of Rolls-Royce handle engines from more than 50 international airlines. Security and reliability are at the heart of our work.

Filed in German · English published by the European Commission

I work in the steel and iron sector, and I would like to share observations on the European Commissions initiative to extend the scope of the Carbon Border Adjustment Mechanism (CBAM). 1. Downstream products: Extending CBAM to include steel-based downstream products will significantly affect global supply chains.

We welcome the Commissions initiative to strengthen the Carbon Border Adjustment Mechanism (CBAM) through the extension to downstream products, the introduction of anti-circumvention measures, and the revision of electricity emissions rules. These steps are crucial to prevent carbon leakage and to ensure fair competition between EU and non-EU producers.

Dear Sir/Madam, here attached is the letter sent on 23rd June 2025 by Serbian TSO, Elektromreza Srbija, to European Commission, Energy Community Secretariat and EU Delegation in the Republic of Serbia. By this letter EMS urged the European Commission to reconsider the application of CBAM to electricity imports from the EnC Contracting Parties, particularly in advance of full market integration.

Please find attached the paper of the Ministry of Economic Affairs (R.O.C.), which sets forth our comments and recommendations concerning this consultation. Include recommendations concerning downstream products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Re: Carbon Border Adjustment Mechanism – downstream extension, additional anticircumvention measures and rules for the electricity sector To whom it may concern, The Association of Equipment Manufacturers (AEM) 1 is reaching out on behalf of the off-road equipment manufacturing industry regarding the EU Commission’s consultation for their Carbon Border Adjustment Mechanism (CBAM) – downstream extension…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Business & Science Poland wishes to present its position and highlight key issues from the perspective of energy-intensive industries and producers competing on global markets. We welcome the initiative and the Commissions recognition of the challenges arising from the current CBAM design. Please find our detailed position paper attached.

o Proving CBAM compliance of imported electricity needs reliable tracking of such electricity. Preventing double counting of the same renewable attributes is essential to ensure impact of the intended CBAM measures.

Founded in 2020, Elyse Energy is an independent French industrial SME, pioneering the production of low-carbon molecules. Active in France and on the Iberian Peninsula, Elyse Energy contributes to strengthening Europes energy independence.

Moeve welcomes the opportunity to contribute to the European Commissions call for evidence on the extension of the Carbon Border Adjustment Mechanism (CBAM) to some downstream products, anti-circumvention and rules on electricity emissions.

This document, prepared by the DigitalTrade4.EU consortium, provides strategic input for the revision of the EUs Carbon Border Adjustment Mechanism (CBAM) and the New Legislative Framework (NLF). It proposes the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to support secure, transparent, and efficient cross-border trade.

Ragn-Sells welcomes the Commissions initiative to extend the scope of CBAM to cover certain steel and aluminium-intensive downstream products. We agree with the Commissions assessment, as stated in its call for evidence, that downstream products may lead to increased carbon leakage if they are excluded from the CBAM scope.

CBAM was originally intended for raw materials such as iron and steel, before its scope was quickly extended to processed goods during the legislative process. The envisaged mechanism and the collection of the necessary data may be realistic for raw materials, but for processed goods, which are often traded in very small quantities via multi-level distribution channels and traders, the required information is…

Jernkontoret, the Swedish steel producers association support the consultation paper from Eurofer, attached. Concerning the extension to downstream goods the Swedish iron and steel industry are deeply concerned about the risk of circumvention due to the possibility to avoid CBAM cost by further processing outside EU.

Warsaw, 20.08.2025 Internal mark: NNR/21/2025 Applies: Response to the European Commission's call for comments: Carbon border adjustment mechanism – extension to downstream goods, additional anti-circumvention measures and legislation for the electricity sector The Grupa Azoty Group [Grupa Azoty] would like to thank you for the opportunity to refer to the important regulatory mechanism - CBAM.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EAFA POSITION: CBAM DOWNSTREAM EXTENSION August 2025 About us The European Aluminium Foil Association (EAFA) is the main trade association representing companies engaged in the rolling and rewinding of aluminium foil and the manufacturing of semi-rigid alufoil containers and household foil in Europe. With its more than 40 members, the organisation represents the total aluminium foil rolling market in Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Certain countries with a vast territory and a unified power supply system may still include separate, unconnected regions or a regional structure with different emission factors in each region. Using a single default emission factor for an entire country seems inappropriate, as it does not reflect the actual intensity of GHG emissions or the structure of electric power generation in individual regions.

The European Steel Processors Association (ESPA) welcomes the EUs efforts to strengthen the Carbon Border Adjustment Mechanism (CBAM) as a key tool to prevent carbon leakage and support the decarbonisation of the steel sector. ESPA supports extending CBAM to downstream products to address carbon leakage risks across the value chain and advocates for robust anti-circumvention measures to ensure effectiveness.

Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anticircumvention and rules on electricity emissions Public consultation 01 July 2025 - 26 August 2025 CIP comments Introduction The Portuguese Business Confederation (CIP) supports the EU’s climate objectives and recognizes CBAM as a relevant tool to prevent carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European producers of steel-based products are currently being discriminated against under the existing legal framework. While CBAM, ETS charges, and quantitative quotas apply to primary steel products (e.g. wire rods, rebar, sheets), no such mechanisms exist for processed or derivative steel products.

Google welcomes the opportunity to respond to the European Commission's public consultation on the Carbon Border Adjustment Mechanism (CBAM), particularly regarding the rules for the electricity sector and the accurate accounting of embodied electricity emissions in imported products.

On behalf of Beijing Oriatec Co., Ltd., a China-based institution specializing in CBAM compliance consulting and training, we respectfully provide recommendations on the European Commissions proposal to extend the scope of the CBAM. These suggestions draw upon two years of practical experience and research with exporters.

The European Carbon Border Adjustment Mechanism (CBAM) is fundamentally pursuing the right goal: climate protection by preventing carbon leakage. In its current form, however, the CBAM fails to achieve this goal, and at the same time jeopardizes the international competitiveness of European industry. Discussions about extending CBAM to downstream steel and aluminum products miss the point.

The Japan Business Council in Europe (JBCE) would like to share its concerns regarding the proposed extension of the Carbon Border Adjustment Mechanisms (CBAM) scope for three reasons: (i) lack of proportionality, (ii) difficulty in complying on the basis of actual emission data, and (iii) insufficient alternative measures to enable compliance.

Hy2gen AG welcomes the European Commissions initiative to strengthen the Carbon Border Adjustment Mechanism (CBAM). As a developer, owner and operator of renewable hydrogen (RFNBO) projects and derivatives (ammonia, methanol, sustainable aviation fuels and methane), we fully support CBAMs objective of preventing carbon leakage and ensuring a level playing field for EU producers.

Call for evidence: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions In general, we do not support the reduction of free allowances allocation, particularly due to the CBAM factor in strategic sectors, such as chemical production, including fertilizers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We appreciate the opportunity to provide feedback on the proposed extension of the Carbon Border Adjustment Mechanism (CBAM) scope. Due to the complexity and length of our input, we have uploaded a detailed document outlining our concerns and recommendations, particularly regarding the impact on downstream aluminum products and industries.

Dear Members of the European Commission. Please find enclosed a letter, on behalf of and on behalf of the companies, COINALDE S.COOP., a Spanish company located in Vitoria-Gasteiz, Spain, and COINALDE POLSKA Sp z.o.o, a Polish company, located in Jelcz-laskowice, Poland, both manufacturers of nails, for the construction, packaging and pallet manufacturing sectors, and which use iron or steel wire rod as the only raw…

Filed in Spanish · English published by the European Commission

Safeguarding the chemical sector from an unintended CBAM scope expansion Cefic briefly responds to the consultation of CBAM downstream goods scope expansion by requesting the Commission to avoid the inclusion of the chemicals NACE codes via a backdoor mechanism.

From the perspective of the steel industry in Germany and the EU, the CBAM can be an effective instrument for preventing carbon leakage and supporting investment in the decarbonization of the steel industry. However, a fundamental precondition for this is that its effectiveness is ensured from the very beginning through comprehensive regulations.

Our company manufactures a broad range of steel-intensive downstream goods that are designed, engineered and produced within the European Union. Over the past decade, we have made significant investments in the EU to support its climate objectives while sustaining high-quality industrial employment in our region. However, the commercial environment in which we operate may evolve rapidly and dramatically.

NLMK Belgium Holding (NBH) supports extending CBAM to downstream products to address carbon leakage risks across the value chain and advocates for robust anti-circumvention measures to ensure the mechanisms effectiveness. However, NBH cautions against introducing the melted and poured concept, as it would undermine CBAMs environmental objectives and create unnecessary trade barriers.

Port of Rotterdam | CBAM The European Union faces significant challenges in its pursuit of a sustainable and prosperous future. Amid rising geopolitical tensions and global competition, a strong and resilient Europe is essential to maintaining its economic strength through sustainable means.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Siemens Energy is pleased to provide feedback on the EU Commissions consultation regarding the Carbon Border Adjustment Mechanism (CBAM) - focusing on downstream extension, anti-circumvention, and rules on electricity emissions. This engagement enables us to influence the final design of the EUs carbon pricing mechanisms, thereby supporting the competitiveness of the EU cleantech industry.

Our company manufactures a wide range of steel-intensive downstream goods that are fully designed, engineered and built in the European Union. Over the past decade, we have invested significantly in the EU to support the EU’s climate goals, while ensuring quality industrial employment in our territory. However, the competitive environment in which we operate is rapidly evolving.

Filed in Italian · English published by the European Commission

The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, strongly advises against the horizontal expansion of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. The position paper argues that such an expansion would be premature, administratively unworkable, and counterproductive to the EU's climate and economic goals.

EIFI, the European Industrial Fasteners Institute, is the recognized non-profit making organization registered under Belgian law, representing the European Fasteners Manufacturing Industry and its Supply Chain. The European Fastener Manufacturing Industry is committed to a sustainable, competitive, and fair industry.

Finnwatch welcomes the initiative to expand the scope of the carbon border adjustment mechanism (CBAM) to downstream products and encourages the commission to also consider expansion to new products groups. The mechanism has multiple overlapping benefits for the goals of climate policy.

The European Solar Manufacturing Council (ESMC) urges the European Commission to extend the Carbon Border Adjustment Mechanism (CBAM) to key downstream solar products, including: Solar PV modules (finished photovoltaic panels) Mounting structures (aluminium and steel frames that support solar panels) Solar trackers (motorized systems that orient panels toward the sun) We also recommend that the Commission adopt…

As stakeholders from the Turkish foundry industry, we would like to share our concerns and perspectives regarding the proposed extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. 1.

Regulation (EU) 2023/956, which was adopted on 31 August 2025. The entry into force of December 2025 is currently limited to upstream products. As soon as a further production step takes place, most of these products fall outside the scope of the Regulation. In our view, it is therefore likely that further processing steps will be transferred to third countries in order to avoid the cost of carbon pricing.

Filed in German · English published by the European Commission

Public National Energy System Operator Faraday House Gallows Hill Warwick CV34 6DA neso.energy 25 August 2025 NESO response to the European Commission call for evidence on the EU Carbon Border Adjustment Mechanism and rules for the electricity sector Who we are The National Energy System Operator (NESO) was established on 1 October 2024.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of the Ministry of Environment (MOENV) of Taiwan, we would like to offer our comments on the Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. We appreciate the opportunity to provide our feedback and contribute to the development of a robust and effective EU CBAM.

EXECUTIVE SUMMARY HSCZ acknowledges the theoretical rationale behind expanding the scope of the CBAM to downstream products, but from a practical perspective such expansion raises complex issues: The primary goal of the CBAM Regulation to ensure a level playing fieldshould remain the focus.

SMEunited supports addressing the risk of circumvention and resulting unfair competition for small and medium enterprises in Europe with regards to the Carbon Border Adjustment Mechanism (CBAM), for example in the iron/iron/steel and aluminium processing industry.

Global carbon pricing next to boosting more renewable energies and energy efficiency is key for combating climate change. It levels the playing field, rewards innovation and drives emission reductions cost effectively. MedTech Europe shares the general motivation of preventing carbon leakage in support of fair carbon pricing as long as global climate ambitions differ.

The CBAM (Carbon Border Adjustment Mechanism) is a completely new measure that has not yet been tested and is incomplete in its design. In its current form, it risks jeopardising the competitiveness of European industry and not providing effective protection against carbon leakage. A substantial improvement of the mechanism is urgently needed to achieve its objectives.

Filed in German · English published by the European Commission

Proposal of Recommendations for Expanding the Scope of Regulated Products: 1. It is not advisable to expand the regulatory scope of the CBAM to include chemicals, polymers, or plastic products (1) The raw materials and production processes associated with these products are highly diverse and technically intricate, posing considerable challenges to trace and calculate embedded emissions.

Include nickel in CBAM - create European competitiveness As a leading European producer of low-carbon metals, Boliden proposes the inclusion of all intermediate and refined nickelproducts, excluding nickel concentrate, in CBAM. Its critical that the inclusion of nickel into CBAM is extended vertically to finished products.

From the point of view of the steel industry in Germany, CBAM must be a useful tool to prevent carbon leakage and to accompany investments to decarbonise the steel industry, as the EU has decided that the protection afforded by free allocation to date will soon be fully phased out. However, it is essential that its effectiveness is ensured from the outset by comprehensive rules.

Filed in German · English published by the European Commission

TIC Council, the global association of the Testing, Inspection and Certification (TIC) sector, represents the independent verifiers in the CBAM regulation. TIC Council supports the extension of CBAM to downstream products and the anti-circumvention measures proposed by the European Commission. This proposal will act against international carbon leakage and align CBAM more with the EU ETS.

Hy24s portfolio companies have more than 5 GW of electrolysis capacity in advanced development stages across multiple EU countries. As such, we firmly support the EUs strategic imperative to accelerate the transition to a clean, hydrogen-powered industrial sector.

As the European Union seeks to meet both climate and circular economy goals while boosting its competitiveness, the extension of the Carbon Border Adjustment Mechanism (CBAM) presents a unique opportunity to introduce financial incentives that simultaneously address carbon leakage and drive the transition toward a truly circular economy.

Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anticircumvention and rules on electricity emissions Feedback from the Czech Chamber of Commerce The Czech Chamber of Commerce welcomes the opportunity to comment on the call for evidence for an impact assessment on CBAM – downstream extension, anticircumvention and rules on electricity emissions. You can find the comments of our members below.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Members of the European Commission, The Japan Iron and Steel Federation is a nationwide representative body of the Japanese steel industry and its members consist of the country's major iron and steel producers, trading companies, and organizations engaged in steel distribution. We hereby submit our views regarding the Carbon Border Adjustment Mechanism (CBAM).

Joint position on EU-UK electricity exchanges Feedback on the Extension of the scope of the carbon border adjustment mechanism to downstream products and anticircumvention measures – 08.2025 Unlocking the full potential of current and future electrical interconnections across the Channel and in the North Seas is vital to achieving the net zero objectives for both sides The EU and the UK share similar commitments and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our opinions are as follows: A.Proposal of Recommendations for Expanding the Scope of Regulated Products (1)It is not advisable to extend the regulatory scope of the CBAM to include products incorporating items covered under the CBAM as components. (2)It is not advisable to expand the regulatory scope of the CBAM to include chemicals, polymers, or plastic product. (3)Require information disclosure and transparency.

1 Studi & Ricerche antifascista [name removed] revisore dei conti V.Cristalliera 7 10129 Torino IT www.marcobava.it Tel [phone removed] [email removed] TO.12.07.25 Proposta di studio di EBC-EnergiaBeneComune Questo studio ha l’obiettivo di indicare gli argomenti da attuare per un sistema energetico possibile ed efficiente : 1) Struttura di base energetica elettrica stabilizzata dall’H2 2) L’H2 potrebbe essere…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To the attention of European Commission Directorate-General for Taxation and Customs Union (DG TAXUD) Brussels, Belgium 18 August 2025 Subject: CBAM – Request for Downstream Extension and Inclusion of Steel Strand and Derivative Products Public Consultation uploaded feedback Dear Sirs, The CBAM Regulation (EU 2023/956), which establishes the Carbon Border Adjustment Mechanism, entered into force on 17 May 2023 and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To the attention of European Commission Directorate-General for Taxation and Customs Union (DG TAXUD) Brussels, Belgium 18 August 2025 Subject: CBAM – Request for Downstream Extension and Inclusion of Steel Strand and Derivative Products Public Consultation uploaded feedback Dear Sirs, As a European producer of steel wire (bright wire and black annealed) and metal fibers, we respectfully submit this letter to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To the attention of European Commission Directorate-General for Taxation and Customs Union (DG TAXUD) Brussels, Belgium 18 August 2025 Subject: CBAM – Request for Downstream Extension and Inclusion of Steel Strand and Derivative Products Public Consultation uploaded feedback Dear Sirs, As a European producer of steel wire and steel strand, we respectfully submit this letter to express our deep concern regarding the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEC and IVSH generally support the EUs CBAM mechanism but warn that the current CBAM design creates major competitive distortions. Excluding downstream products in our sector (e.g., cookware, cutlery, household goods with >70% metal content) risks carbon leakage, production shifts, and job losses.

Germanwatch welcomes the European Commission’s current reform initiative, in particular with regard to downstream scope expansion and the prevention of CBAM circumvention. However, the established timetable for CBAM implementation, together with the parallel phased reduction of the free allocation of emission permits, should be maintained.

Filed in German · English published by the European Commission

In Türkiye, renewable energy investments can be made under two models defined in the Electricity Market Law No. 6446: licensed and unlicensed generation. A license, per the Law, is the formal authorization to operate in the electricity market. Conversely, Article 14 outlines exceptionstermed unlicensed generationthat are exempt from licensing and company establishment.

1. In the absence of guidance, i.e. the regulations implementing the CBAM template, we request the annual vacatio Legis to become final. Steel purchases are made 12 months in advance sometimes 7 months in production + 3 months transport organisation and transport (via Africa) + 2 months for delays because they are usually the case.

Filed in Polish · English published by the European Commission

Draft ID: 122dc547-bd81-4f32-9057-9227accd1eb8 Ref. Ares(2025)6810009 - 22/08/2025 Date: 02/07/2025 11:04:28 Carbon Border Adjustment Mechanism – downstream extension, additional anticircumvention measures and rules for the electricity sector Fields marked with * are mandatory.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Datum: 22.08.2025 An: European Commission Von: Getriebebau Nord Betreff: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions CBAM: A Threat to Europe’s Industrial Competitiveness The European Carbon Border Adjustment Mechanism (CBAM) is fundamentally pursuing the right goal: climate protection by preventing carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Warsaw, 22nd August 2025 ORLEN SA contribution to the European Commission public consultation on Carbon Border Adjustment Mechanism – downstream extension, additional anti-circumvention measures and rules for the electricity sector I. ORLEN GROUP: • ORLEN Group is an integrated, multi-utility corporation primarily active in Central Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

(This a summary of Técnicas Reunidas' position, comprehensive feedback can be found in the attached document) Técnicas Reunidas (hereinafter TR) is a global leader in engineering and construction, specialising in the design and execution of complex industrial facilities.

Flender International GmbH, a leading company for manufacturing mechanical and electrical drive systems, believes that the current CBAM design poses a risk to the competitiveness of EU exporting machinery manufacturers.

From today's perspective, the design of the CBAM still has serious gaps that significantly reduce the effectiveness of the instrument and therefore need to be closed immediately. CBAM is unsuitable for ensuring the competitiveness of European metalprocessing companies with an export focused business model becasue there is no coverage of finished goods (downstream goods) garanuteed, comes with high administrative…

From the perspective of the steel industry in Germany and the EU, the CBAM can be an effective instrument for preventing carbon leakage and supporting investment in the decarbonization of the steel industry. However, a fundamental precondition for this is that its effectiveness is ensured from the very beginning through comprehensive regulations.

The FachverbandToolindustrie e.V. (FWI) welcomes the European Commission’s initiative to examine the extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. Our sector is under increasing pressure due to its exclusion from the Carbon Border Adjustment Mechanism (CBAM).

Filed in German · English published by the European Commission

The Federation of Employers of Ukraine would kindly ask the European Commission to consider applying the provisions of Article 30 (7) of Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism (hereinafter referred to as the Regulation) to Ukrainian manufacturers of goods subject to the Regulation.

EXECUTIVE SUMMARY HSSK acknowledges the theoretical rationale behind expanding the scope of the CBAM to downstream products, but from a practical perspective such expansion raises complex issues: The primary goal of the CBAM Regulation to ensure a level playing fieldshould remain the focus.

The European Commission Directorate-General for Taxation and Customs Union 17 August 2025 Public consultation uploaded feedback Extension of the product scope of the EU CBAM to prevent further carbon leakage and potential circumvention The Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism (the CBAM Regulation)1 entered into force…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We recommend to keep the course on CBAM and the EU ETS free allowance phase out. Any watering down will cause a downward pressure on CO2 prices, shrink the Innovation Fund, and lower pressure on other countries to implement their own ETSs.

Please find full response in document attached. The consultation highlights the need to clarify and strengthen PPA requirements to ensure CBAM is effective. EnergyTag welcomes this focus and offers the following recommendations, which should apply to the use of PPAs for both direct electricity imports and for electricity embedded in products.

Air Liquide welcomes the introduction of CBAM as a tool to address carbon leakage, and to foster decarbonisation in the EU and abroad. However, it will be crucial for CBAM to be applied in a workable manner to ensure decarbonization of industry, while ensuring the competitiveness of EU industry.

STELLUNGNAHME CO2-Grenzausgleich (CBAM) Die EU hat 2023 die Einführung eines CO2-Grenzausgleichsmechanismus (Carbon Border Adjustment Mechanism – „CBAM“) beschlossen. Aus der Gruppe der Nichteisen (NE)-Metalle ist zunächst Aluminium erfasst. Die WVMetalle hat sich von Anfang an gegen einen CBAM ausgesprochen, fordert heute noch seine Abschaffung und die Beibehaltung der bestehenden Carbon-Leakage-Maßnahmen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European tool industry strongly welcomes the European Commission´s initiative to consider the extension of CBAM to downstream products. Our industry is under growing pressure due to its exclusion from the Carbon Border Adjustment Mechanism (CBAM).

The European Association of Chemical Distributors (Fecc) welcomes the opportunity to contribute to the Commissions consultation on the potential extension of the Carbon Border Adjustment Mechanism (CBAM). We support the EUs climate ambition and recognise CBAM as an important tool to ensure a level playing field.

We are a European industrial group with multiple business units and global supply chains. Our activities span manufacturing, engineering, and related services. As an importer of goods falling under the current CBAM scope, we are directly involved in the ongoing implementation process and thus have first-hand insight into the operational challenges faced by industry stakeholders.

The European Trade Indexes Registry (EUTIR) is a proposed EU-level digital infrastructure designed to enhance trust, transparency, and interoperability in cross-border trade. By securely registering and verifying metadata of trade-related datasetssuch as those used in the Carbon Border Adjustment Mechanism (CBAM), Digital Product Passports (DPP), and electronic Freight Transport Information (eFTI)EUTIR acts as a…

Carl Zeiss AG, a leading global tech company in optics and optoelectronics, supports the initiative to extend the Carbon Border Adjustment Mechanism (CBAM). We stress the need for a balanced and workable framework that effectively prevents carbon leakage while recognising the realities of downstream supply chains.

Filed in German · English published by the European Commission

AFV Beltrame Group, founded 1896, operates 7 sites in IT, FR, CH, and RO, with more than 2k employees and over 2mil t/year of steel, sold in over 40 countries. Our portfolio covers construction,shipbuilding,earthmoving machinery,oil&gas,energy,automotive,and agricultural equipment.

The exemption limit for the annual import volume of CBAM items below 5 tonnes should also apply to goods received in the future, as it drastically reduces the burden on small and medium-sized enterprises. In general, there are far too many EU regulations in this direction (EUDR, F-gas, Packaging Regulation) to name just a few, whose implementation in small and medium-sized enterprises generates a considerable…

Filed in German · English published by the European Commission

In Branchehuset we acknowledge the concern that the current CBAM-rules might lead to a future increase in imports of downstream products from non-EU countries. However, we are concerned about the potential burdens and consequences of such an extension and wish to highlight that the full impact of the current scheme has yet to be realized.

Feedback on the proposed CBAM extension We are a European industrial group with multiple business units and global supply chains. Our activities span manufacturing, engineering, and related services. As an importer of goods falling under the current CBAM scope, we are directly involved in the ongoing implementation process and thus have first-hand insight into the operational challenges faced by industry…

20th August 2025 Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions Feedback on the Consultation (01 July 2025 - 26 August 2025) FVSB – Association of the German Lock- and Fittings-Manufacturers FVSB represents approximately 70 companies in Germany. Most of these companies are privately owned, many of them being medium size enterprises.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NPC Ukrenergo, the Transmission System Operator of Ukraine, respectfully requests consideration of a deferral in the application of the Carbon Border Adjustment Mechanism (CBAM) to electricity export operations from Ukraine. Ukraine is in the process of fully integrating its power system into the European electricity market.

final 18. August 2025 Ref. Ares(2025)6713005 - 19/08/2025 Carbon Leakage bei CBAM (und ETS 1 Gratiszuteilungen) Schwerpunkte: Exportregelung, downstream Produkte und Gratiszuteilung A) Ausgangslage Die EU-KOM plant nach den CBAM-Vereinfachungen mit dem – von der Industrie begrüßten „Omnibus Vorschlag“ weitreichende Reformen für den Carbon Border Adjustment Mechanism (CBAM) und für den EU-Emissionshandel 1 (ETS 1).

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIR3: EA0001321 Port Authority of Valencia Contributions to the EU Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions - Call for Evidence The Port Authority of Valencia (PAV) strongly welcomes the opportunity to contribute to the public consultation on the extension of carbon border adjustment mechanism (CBAM) to downstream products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The textile and apparel sector is highly fragmented and deeply globalised. Production involves multiple stages, from raw material sourcing to finishing, often spread across several countries. In practice, downstream CBAM coverage could affect the sector indirectly through key inputs such as chemicals, zippers, decorations, and other aluminium- or steel-based components that are integral to apparel manufacturing.

I would like to give feedback from the perspective of a mid-sized EU production company and raise my concerns: 1. Downstream The current design of the Carbon Border Adjustment Mechanism (CBAM) disproportionately disadvantages medium-sized producers of metal goods such as locks, fittings, and hinges (HS 8301, 8302).

Hašpl a.s. supports European Union measures aimed at protecting European industry and ensuring fair conditions of economic competition , but only on the condition that the current system of protective measures and their planned replacement do not remain incomplete and selective, as this creates unequal conditions for individual production segments. Our statement in the appendix

We highly appreciate the progress made on CBAM in the Steel & Metals Action Plan earlier this year. Particularly the recognition and the planned solution to Resource Shuffling in that document is essential to avoid carbon leakage and enable investments in the EU.

Currently, CBAM applies to imports of wind towers classified under tariff heading 7308.20.00.11, meaning that importers of towers manufactured mainly in third countries must bear the cost derived from the adjustment for embedded carbon emissions.

We respectfully request the introduction of a minimum reporting weight per CN code under the CBAM framework. This would prevent the disproportionate requirement to report extremely small quantities. For example, a component that weighs only 5 grams and 5 units is purchase.

Our issue with CBAM is it does not take account of circular economy or secondhand products in any way we can find We deal in surplus/downgrade/second hand pipe We have EPDs demonstrating that the carbon savings are between 70 and 97% for these products but cannot see a way to use the EPDS in CBAM submissions as we seem to have to use the product codes that are the same as for new production.

We hereby express our agreement with the methodology already established by the Regulation for calculating emissions of electricity as a CBAM good. The use of the CO2 emission factor (resulting from dividing the CO2 emission data of the electricity sector by the gross electricity generation based on fossil fuels in the relevant geographic area), by default, is the best approach, as marginal technologies (in general…

FEC and IVSH generally support the EUs CBAM mechanism but warn that the current CBAM design creates major competitive distortions. Excluding downstream products in our sector (e.g., cookware, cutlery, household goods with >70% metal content) risks carbon leakage, production shifts, and job losses.

The Customs Code allows Norwegian companies to be the declarant and importer of an import declaration in Sweden, i.e. it is possible for these companies to make an import declaration in their own name or to have recourse to a direct customs representative.

Filed in Swedish · English published by the European Commission

On behalf of the German and European Rubber Industry we ask to NOT extend CBAM to polymers and organic chemicals. We are representing 220 companies, producing a wide range of industrial products within the EU, elastomers and organic chemicals being their core material. All European mobility, the construction sector, baby- and healthcare, food production as well as drinking water supply relies on our products.

Call for Evidence for an Impact Assessment Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention, and rules on electricity emissions The International Tracking Standard Foundation (I-TRACK Foundation) welcomes the adoption of the European Commissions Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) in May 2023.

We are a German manufacturer of door locks and fittings and we manufacture only our products in Germany. CBAM will make the materials entering our products more expensive and we will be forced to pass on the increased costs to our customers as higher prices. If our competition is such that the same products (closers and fittings) are imported from abroad, they will not be automatically affected by CBAM.

Filed in German · English published by the European Commission

CBAM call for evidence – EEB position The CBAM review must recognise its role of climate measure intended to help meeting the EU climate neutrality goal and promote decarbonisation globally1, and that relevant and objective data2 is needed to support circumvention claims, which to date is very limited, given that CBAM is still in its transitional phase and many pieces of secondary legislation have not been defined…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cern, the European Organization for Nuclear Research, is one of the world's largest centers for scientific research, focusing on fundamental physics to understand the universe's composition and workings. As main role of collaborative missions, the impact of such regulation is quit huge for an international organization.

Neither the EU nor individual countries can meet their climate targets without decarbonizing the steel industry, and it is clear that climate ambition must be delivered through innovation and investments in Europe not deindustrialization. It is therefore key to create the conditions and predictability for companies to continue reducing emissions through investments in innovative technologies and solutions.

1000 BRUSSELS Belgium Transparency Register: 825150451993-07 VAT Number: BE 0534.680.034 EUROPEAN COMISSION Directorate-General for Taxation and Customs Union, Unit C5 (Economic Analysis and Taxation of Exempted Sectors) Carbon Border Adjustment Mechanism (CBAM) Subject: CBAM: Public consultation on the extension of CBAM to downstream products In general EBMA highly appreciates the European Commission e orts to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From the perspective of a certified transmission system operator of Montenegro (CGES), we considers that such application of CBAM would be incompatible with the ongoing and carefully structured integration of the EnC CPs into the EUs internal electricity market. 1.

Ensuring the Competitiveness of EU Refineries in a Global Market EU refineries operate in globally competitive markets but face significantly higher operating costs than their non-EU counterparts, driven by elevated energy and labour expenses. The introduction of carbon pricing further increases this burden—costs that are not borne by the vast majority of competitors outside the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our Proposal We respectfully call upon the European Commission to implement the following urgently: Expand CBAM coverage to include all downstream steel products and any goods containing carbon steel. Apply carbon tariffs based on the steel content by mass. For instance: - 100% steel-based goods should be subject to the full CBAM adjustment. - Products with partial steel content should be charged proportionally.

Who we are The Electromechanics Synergy Network (ESN) was established in 2024 with the aim of bringing together all European players operating in the electromechanical sector, specifically the supply chain of transformer and electric motor manufacturers, from steel production to the finished product.

Filed in Italian · English published by the European Commission

Who we are The Electromechanics Synergy Network (ESN) was established in 2024 with the aim of bringing together all European players operating in the electromechanical sector, specifically the supply chain of transformer and electric motor manufacturers, from steel production to the finished product.

Filed in Italian · English published by the European Commission

Good day, i'm not saying that CBAM isn't good tool but frankly speaking i'm really disappointed with implementation. It's August and i don't know benchmarks..i don't know list of companies who can verify my suppliers if their provided data are correct. I have to place orders for next year but how we can do it without such information?? This will increase only cost for us and i have no time to prepare it.

We welcome the European Commissions efforts to expand the scope of CBAM and strengthen its role in supporting climate objectives. However, in its current design, there is a significant risk of reverse carbon leakage: imports may bear CBAM costs, while equivalent domestic production can avoid them under the ETS.

Carbon Border Adjustment Mechanism (CBAM): Downstream Extension, Anti-Circumvention Measures, and Electricity Emission Rules 1 U About Us The DigitalTrade4.EU consortium envisions a seamlessly interconnected Europe and neighbouring regions powered by harmonized standards for the digitalisation of trade documents and processes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FuelsEurope, the EU conventional, renewable and low carbon fuels and industrial value chains products manufacturing industry, supports the EUs goal of climate neutrality by 2050, recognising that achieving this target will require not only breakthrough technologies, but above all, substantial and timely investments supported by an improved, stable and predictable policy framework.

On behalf of our Association (Eurostress Information Service European Producers of PC Wires and Strands), we respectfully submit, in the attached file, a letter requesting your consideration with regard to the scope of products included in the Carbon Border Adjustment Mechanism (CBAM) with our allegations on the extension of CBAM to downstream products.

TÜV SÜD Bangladesh (TSB) appreciates the opportunity to contribute to the European Commissions initiative on the future direction of the Carbon Border Adjustment Mechanism (CBAM). As a technical consultancy active in Bangladesh, providing services such as Feasibility Studies, Project Management, Energy Audits, Science Based Targets (SBTi) Advisory, and GHG Emission Surveys, we fully support the EUs ambition to…

The goal of reducing the burden on the planet is important to all of us. In order to achieve the goal, we believe it is important to create a level playing field for all stakeholders and to encourage everyone to follow it. Our efforts to reduce our own products for CO2 pollution have to go to a competition that will be decided on a different playground – the price.

Filed in German · English published by the European Commission

VCI consultation contribution to the prospection of a CBAM down-stream extension NOT CBAM REPORT FOR CHEMIE: The Chemical Industry Association (VCI) continues to be critical of the Carbon Border Adjustment Mechanism (CBAM).

Filed in German · English published by the European Commission

Regarding the Call for Evidence CBAM downstream extension, we think that, if we want to prevent carbon leakage, it is absolutely mandatory to extend CBAM scope to cover products downstream from goods currently in scope. Below we try to explain, with the examples of products that we are familiarized with, the production chain, that makes evident that if we dont cover downstream products, we will have carbon leakage.

The European XFEL is a research facility of superlatives. As an international non-profit company located in the Hamburg area in Germany it operates a 3.4 km-long X-ray laser, which produces X-rays of unique quality (27 000 times per second and with a brilliance that is a billion times higher than that of the best conventional X-ray radiation sources) for studies in physics, chemistry, the life sciences, materials…

Introducing a carbon tax on steel raw material (reels; dishes; sheets) to protect our industry and needed. However, the import of semi-finished or modified or processed finished products is not taxed. This makes it possible to import products that have been manufactured with high carbon energy and/or with an unfavourable carbon impact.

Filed in French · English published by the European Commission

European Union Regulation 2023/956, which will come into force on December 31, 2025, currently only affects upstream products. As soon as a further production step takes place, most of these products fall outside the scope of the regulation. In our view, this makes it likely that further processing steps will be relocated to third countries in order to avoid the costs of CO2 pricing.

Please find enclosed SPC Spain’s contribution, in PDF format, to the public consultation opened by the European Commission on: Carbon Border Adjustment Mechanism (CBAM): extension to downstream products, anti-circumvention measures and rules on electricity emissions

Filed in Spanish · English published by the European Commission

1. Financial Impact and Implications for Green Transition The proposed extension of the CBAM scope to include downstream products will directly increase carbon-related costs for exporters, particularly in energy-intensive sectors such as steel and aluminium.

The CBAM transitional phase will end on 31 December 2025. From that point onwards, the definitive regime will come into force, gradually phasing out free ETS allowances and introducing the obligation to purchase CBAM certificates for goods listed in Annex I.

To purchase steel product worldwide we need 1 year in advance to be produced and delivered . Purchase decisions are made based on 1 eur/ton of steel. We do not know if CBAM charges will be 30 or 100 eur/TO. The problem is that we do not know what will be the costs/ charge of one ton of steel according to CBAM regulations. Why we still do not have confirmation of : 1. formula CBAM and rules for the calcuation.

The Federal Association of Glasindustrie e.V. (BV Glas) represents the interests of the energy-intensive glass industry in Germany. The sector produces a variety of products that can be directly affected by both the Carbon Border Adjustment Mechanism (CBAM) and indirectly through their integration into complex value chains.

Filed in German · English published by the European Commission

The Fundacion Valenciaport (FV), an Applied Research, Innovation & Training centre providing services to the port and logistics cluster (https://www.fundacion.valenciaport.com), strongly welcomes the opportunity to contribute to the public consultation on the extension of carbon border adjustment mechanism (CBAM) to downstream products.

We urge the Commission to include customs codes 73110610, 73121065 and 73121069 in CBAM. These products are critical in the European steel market and face the same carbon leakage risks as other steel products already covered, such as PC wire (72171090). More than 95% of PC strand is made from wire rod (HS 7213, 7221, 7227), which is already included in CBAM.

Sandbags recommendations: - For steel and aluminium, address scrap-related circumvention by either: Attributing emissions to both pre- and post-consumer scrap, and including scrap as a CBAM-covered input and applying country-level default values, or Using systematic default values - For cement: Apply systematic default values, to prevent resource reallocation without real emissions reductions - Improve indirect…

We agree that it is needed to include downstream steel and aluminium products in CBAM, but also to include other measures to track the ultimate origin of aluminium and steel, as there is scope for producers on the EU's borders using renewable electricity such as Aluminij Mostar to resell or reshape high carbon-intensity products from elsewhere, undermining CBAM and wasting energy.

Federacciai, the Federation of Italian steel companies, welcomes the opportunity to contribute to the consultation on CBAM downstream extension and additional anticircumvention measures. CBAM, which works alongside the gradual phase-out of free ETS allowances for EU producers, risks to be completely ineffective or even counterproductive in tackling the risk of carbon leakage, if not thoroughly revised before it…

Feedback on the Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures 01/08/2025 RTE strongly supports the Commission’s objective to make European industry cleaner and to encourage cleaner industrial production in non-EU countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Enercluster is a private non-profit organisation created to foster collaboration among companies in the renewable energy sector, with the aim of increasing competitiveness and generating added value. Today, Enercluster represents 98 companies across the renewable energy value chain, including major international players in wind, solar, energy storage, and green hydrogen.

Considering these two categories of products: 8433 19 00 Mowers, and 8428 90 00 Wood chippers, the share of imported machines in the EU market has increased tenfold over the last 10 years. EU-made machines bear a large portion of their total cost in raw materials (mainly steel), making it nearly impossible to compete with imported alternatives.

Assofond is the Italian association representing foundries, including both ferrous metal foundries (such as cast iron and steel) and non-ferrous metal foundries (such as aluminium, bronze, etc.). The foundry sector is an integral part of the national manufacturing industry, producing metal semi-finished products using raw materials such as cast iron ingots, aluminium billets, and ferroalloys.

On behalf of our Association (Eurostress Information Service European Producers of PC Wires and Strands), we respectfully submit, in the attached file, a letter requesting your consideration with regard to the scope of products included in the Carbon Border Adjustment Mechanism (CBAM) with our allegations on the extension of CBAM to downstream products.

Lufthansa Technik is an internationally operating Maintenance Repair and Overhaul MRO company in the field of aviation which serves customers worldwide. We keep airplanes flying and by means of repair contribute to a longer usage of airplanes and parts rather than purchasing of new components or parts.

CELSA Group, as one of Europes leading steel producers, welcomes the opportunity to contribute to the consultation on the Carbon Border Adjustment Mechanism downstream extension, additional anticircumvention measures and rules for the electricity sector.

We fully understand and support the objective of the initiative, namely to ensure that EU-based producers are not placed at a competitive disadvantage. However, we would like to draw the Commissions attention to the fact that under the EU ETS, only installations with certain capacities in the steel and aluminium sectors fall within the scope of the systemthis is not considered at all in the CBAM regulation in the…

1. Postponement of Financial Obligations for Electricity to Q1 2028 Under Article 2(7) and (8) of Regulation (EU) 2023/956, electricity imports can be exempted from CBAM if strict conditions are met, including market coupling with the EU. The first report confirming fulfillment of these criteria was due by 1 July 2025.

ENTSO-E supports the general principles and objectives of the CBAM. There are however still many questions and concerns that would challenge the current reporting obligations of the transitional period as well as the full implementation of the CBAM regulation as of 1 January 2026 for electricity.

In principle, from the point of view of the EU manufacturing industry, it is useful to include in CBAM also finished products which consist predominantly of steel and aluminium, but which do not have a tariff number from Chapter 72,73 or 76. This is because otherwise EU producers do not have competitive advantages.

Filed in German · English published by the European Commission

UNIQ (Union Nationale des Industries de la Quincerie – Union Nationale des Industries de la Quincerie) (Union Nationale des Industries de la Quincerie) ruled in March 2025 in favour of the inclusion of hardware products on the list of downstream products in the CBAM mechanism.

Filed in French · English published by the European Commission

25 July 2025 CARBON BORDER ADJUSTMENT MECHANISM (CBAM) CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT The Shipyards & Maritime Equipment Association of Europe (SEA Europe) represents the European maritime manufacturing industry in 17 countries, encompassing the production, maintenance, repair, retrofit and conversion of all types of ships and floating structures – commercial as well as military – including the full…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BOHEMIA RINGS s.r.o. is the largest Czech manufacturer of hot rolled seamless steel rings and one of the leading European manufacturers. Our customers are European companies operating in various industrial sectors. Our customers have relied on our quality, expertise and reliability for over 30 years.

The current CBAM mechanism primarily targets raw materials (like steel, aluminum, and cement) rather than finished goods, leading to unintended consequences for manufacturers heavily reliant on these inputs. Without the downstream extension, it will create Competitive Disadvantage Against Non-European Finished Goods as imported finished products from outside Europeparticularly from countries with lower carbon…

EUROFER paper: CBAM consultation on circumvention & downstream sectors • • • • • • • • • KEY MESSAGES CBAM circumvention risks are extremely high for steel due to the unique combination of: o Wide product scope & trade flows with numerous third countries; o Heterogenous carbon footprint linked to multiple options of combining production routes and input materials; o Complex and multiple value chains, with several…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In order to make CBAM work, there should be a central database with all relevant import data which can be accessed by the respective economic operator. This will avoid deviations in between the submitted CBAM data and the data which has been submitted to the national customs authorities.

Dear Sir/Madam, We hereby submit our views regarding the public consultation initiated on the extension of the scope of the Carbon Border Adjustment Mechanism (CBAM) and the development of anti-circumvention measures. 1.

While the textile sector is currently outside the scope of the CBAM and its downstream extension, we believe it is relevant to signal its growing contribution to embedded emissions and its exposure to carbon leakage risks.

As the Economic Chamber of Carinthia, we defend the interests of our members. In our advice, we noticed that the scope of the CBAM Regulation takes into account only to a limited extent the current sustainability considerations of companies. The scope is currently too generalistic. It covers both new and second-hand products.

Filed in German · English published by the European Commission

As a European steel producer, we welcome the European Commissions initiative to extend the CBAM to include steel-intensive downstream products. To ensure environmental integrity, fair competition, and industrial resilience, we urge the inclusion of the product groups: 7312 Stranded wire, ropes, cables; 7313 Barbed wire and twisted fencing wires; 7314 Woven mesh and fencing of iron or steel wire; 7315 Chains and…

The EU’s administrative tasks on prohibitions and restrictions (VuB) are increasing and demanding more company employee services, which have a double impact due to the lack of skilled workers. Our government promised to reduce administrative burdens in order to re-legislate. In my view, while CBAM pursues a good environmental and job objective, the burden is double.

Filed in German · English published by the European Commission

METALURGIA S.A. Position Statement in the Consultation on the Extension of the Carbon Border Adjustment Mechanism (CBAM) to Processed Products. Introduction and Position Statement: as a specialized manufacturer of low-carbon wires, we welcome the European Commission's initiative to extend the Carbon Border Adjustment Mechanism (CBAM) to process products.

Slevárny Třinec, a.s., as one of the largest foundries in the Czech Republic and a major European producer of steel and cast iron castings, welcomes and joins the European Commission's initiative to extend the Carbon Border Adjustment Mechanism (CBAM) to the so-called "downstream products", as we are sure that the foundry industry is a really strategic industry.

We are one of the biggest Czech forging companies. We have learnt very important product groups are missing in currently valid CBAM product list. We support the EC's efforts to extend actual CBAM rules by additional downstream products. To secure competitivenes of european forging industry, we herewith ask for implementation of the product groups stated below.

In our view, the EU’s approach to CBAM makes sense, especially in the light of the Green Deal. The complexity of the mechanism is becoming increasingly complex as a result of increasingly small-scale approaches and reporting. This goes hand in hand with the fear that an increasing number of companies will not or will not be able to comply with the CBAM reporting obligation.

Filed in German · English published by the European Commission

CBAM is a very large hurdle for businesses. As we are based in several countries, we need to establish a local registration in each country. There is no possibility to simply upload the data via a multi-country account (via upload)

Filed in German · English published by the European Commission

Dear Sir&Madam; I would like to ask GHG protocol decision about transfering Green energy from one location to others. If we do not have possibility to invest or introduce system in where will produce Green energy in location, and no way to decrease Carbon Footprint. In my opinion, there is no right reason behind and Please check and send your comment about it. thank you

Please find our position in annex. Basic remarks: — An extension of the scope cannot be achieved without having a solution for exports for the current and future scope. If there is no solvent for export, CBAM should be put on hold.

Filed in Dutch · English published by the European Commission

7312 Stranded wire, ropes, cables, plaited bands, slings and similar products, of iron or steel 7314 Cloths (including endless bands), grill, netting and fencing, of iron or steel wire 7320 Springs and spring leaves of iron or steel 7408 Copper wires 7419 Other copper products 8102 Molybdenum and articles thereof, including waste and scrap 8207 Interchangeable tools for hand tools and implements, whether or not…

Extension of CBAM goods to downstream products is i.o.h.o. quite fair. We handle a lot of tariff classifications and classification reviews for our clients and regularly see products made of 99% steel or aluminium not subject to CBAM because of the classification. What we would like to see is a uniform approach to asses if products are included in certain measures (CBAM or other) or not.

MAKING CBAM EFFECTIVE AGAINST CARBON LEAKAGE – FIX THE DESIGN AND ADOPT A STEP-BY-STEP APPROACH Effective carbon leakage measures are crucial to level the playing field and support European industry in its decarbonisation efforts. On 1 January 2026, CBAM enters into its definitive phase. Importers of CBAM goods will then have a financial obligation to pay for the embedded emissions, with payments starting in 2027.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Legitimate requirement for expanding the Carbon Border Adjustment Mechanism (CBAM) The tariff numbers listed below, which are related to PC Strands products (prestressed concrete products) processed by cold drawing and heat treatment, are among the steel commodities forming an integral part of precast concrete products as well as infrastructure construction. There is extensive international trade in these products.

Řetězárna a.s., Polská 48, 79081 Česká Ves, Czech Republic Feedback on the CBAM Downstream Extension As a significant and one of the largest EU producers of welded steel chains with impact to EU strategic industry sectors like energy, military, mining, fishing, transport, automotive, etc., we highly appreciated initiative of the European Commission´s to extend the CBAM to include steel-intensive downstream products.

The big question is how to deal with food. The fertiliser and fuel are two very large cost items in agricultural production and high costs for these in the EU need to be “compensated” in one way or another, either through CBAM, other tariffs or support for agriculture.

Filed in Swedish · English published by the European Commission

Kuźnia Ostrów Wielkopolski Sp. z o.o. Opinion on the Extension of the CBAM to Downstream Products 1. Introduction and Proposal As a manufacturer of forged steel parts and components for rail vehicles and rolling stock, agricultural machinery, the mining industry, as well as the automotive and mechanical engineering sectors, we appreciate the initiative of the European Commission to extend the CBAM to downstream…

Dear Members of the European Commission, We are a consulting firm from China, specializing in research on the EU Green Deal. The following insights are drawn from our first-hand working experience. From an objective perspective, the current scope of goods covered by CBAM reporting has significant loopholes.

Opinion of the Syndicat de la Construction Métalique de France (SCMF) Public consultation Extension of CBAM to laval and anti-circumvention policy * 10 July 2025 The Syndicat de la Construction Métalique de France (SCMF), which represents more than 850 companies in the sector, supports the principle of an ambitious, fair and effective carbon border mechanism (CBAM).

Filed in French · English published by the European Commission

As traders in the steel chain, we see that CBAM, as designed, penalises more those who seek to partially comply than those who completely evade: Default values: they are punitive, do not facilitate compliance. Result: companies avoid reporting or make-up products to avoid adjustment. Processing outside the EU: documentary costs are already incentivising industrial relocation without real emission reductions.

Filed in Spanish · English published by the European Commission

As a French company importing a small amount of steel (less than 50 tonnes per year), we would like to draw attention to the disproportionate effects of CBAM on small importers. 1. Disproportion of administrative burdens The current CBAM framework imposes a heavy administrative burden on small structures (quarterly reporting, return data requirements, complex regulatory compliance) that is not proportionate to their…

Filed in French · English published by the European Commission

As a European manufacturer specializing in hot-formed steel springs, we strongly support the European Commissions proposal to broaden the scope of the Carbon Border Adjustment Mechanism (CBAM) to include downstream products with high steel content.

Dear Members of the European Commission, We are writing to you on behalf of European steel processing companies and in our capacity as Board Member of WAI The Wire Association International, Poland Chapter, and Members of the Management Board of Herco Sp.z o.o.

Westenergy Ltd welcomes the European Commissions initiative and appreciates the opportunity to provide feedback on the extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures. Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland.

In the initial political process of deciding on the CBAM regulations and on the scope of the goods concerned, it was decided to include CN codes 7326 (Articles of iron or steel) and 7616 (Articles of aluminium) as some of the few downstream goods (following the steel and aluminium raw material value chain) in the CBAM scope.

The CBAM mechanism essentially concerns products in chapters 72, 73 and 76 of the customs tariff, i.e. many semi-finished products imported into the European Union by manufacturing companies to produce finished products, while it completely excludes imports of all goods made of iron, steel and aluminium.

As companies, we are not covered by the de minimis rule and are already subject to the CBAM obligation today. Already now CBAM generates higher administrative costs than the current CO certificate prices would do in direct costs. These administrative costs are much more easily mitigated by economies of scale for large companies than for small and medium-sized enterprises (SMEs).

Filed in German · English published by the European Commission

Subject: Feedback on the Extension of the Carbon Border Adjustment Mechanism (CBAM) to Downstream Products and Anti-Circumvention Measures Submitted by: Kystrederiene (The Association of Norwegian Coastal Shipping Companies) Date: 2-6-2025 Introduction Kystrederiene represents the interests of Norwegian short sea and coastal shipping companies that are vital to national supply chains, industrial logistics, and…

From an Indian vantage pointwhere we at Vision360 Management Consulting have been supporting CBAM preparedness for several integrated producersa few grounded reflections emerge. The intention behind CBAMto curb carbon leakage and ensure value chain fairnessis understandable. Extending it to downstream products may appear logically sound on paper.