CBAM's new product list isn't settled. Your deadline already is.

If you import gearboxes, fasteners, radiators or washing machines, there is a good chance CBAM will apply to you from 1 January 2028. There is also a good chance nobody has told you, because the file is still moving and the trade press has been covering the politics rather than the dates.

Here is the part that gets lost: the year that decides your position is 2027, not 2028. That is true whatever the final product list looks like, and it is true even though the law has not been adopted yet.

Where the file actually stands

The Commission proposed the extension on 17 December 2025 (COM(2025) 989), covering 180 downstream CN codes alongside a set of anti-circumvention measures.

The Council agreed its general approach on 12 June 2026. It refined the product list and — the part with the longest tail — instructed the Commission to review annually which further downstream goods should be added.

Parliament's environment committee held an indicative vote on its position on 6 July 2026, with adoption in plenary expected this month. Reporting suggests Parliament wants to go further than the Council on scope. After that comes trilogue, with a final text expected late 2026 or early 2027.

So there are three lists on the table and they do not match. We are not going to quote you a final number of product codes, because there isn't one yet, and every figure circulating today belongs to one institution's draft rather than to the law. Some of the counts being repeated are themselves second-hand: the Council press release and several law-firm summaries are behind access restrictions we could not read directly.

What is not in dispute is the date. All three positions apply the extension from 1 January 2028, with the first declaration due 30 September 2029.

What kind of goods these are

According to the Commission's impact assessment, about 94% of the affected downstream products are industrial supply-chain goods — inputs and components, not things on a shelf. Consumer household products are roughly 6% of the affected import volume.

The categories being discussed across the three positions are consistent even where the counts are not: fabricated metal products, machinery and industrial equipment, vehicle components such as gearboxes and engines, domestic appliances such as washing machines and refrigerators, and metal construction equipment. Passenger cars themselves have been kept out.

The common thread is that these are steel- and aluminium-intensive manufactured goods. This is not CBAM branching into new materials. It is the same two metals, one processing step further along, which is precisely the gap the anti-circumvention part of the proposal is meant to close: today you can import a finished component free of CBAM while the raw metal that went into it would have been in scope.

Why the deadline lands a year early

CBAM obligations do not begin when you file. They begin when you import, and to import in scope you must already be an authorised CBAM declarant.

Two provisions do the work here, and together they move the real deadline forward by a year:

• Article 5(1b) attaches the duty to apply to the expectation of exceeding the threshold, not to the outcome. You are not permitted to wait, cross 50 tonnes, and then apply.
• Implementing Regulation (EU) 2025/486, Article 4(1) gives the competent authority up to 120 days to decide on an application.

Put those together. If you expect to import more than 50 tonnes of newly-covered goods during 2028, your authorisation has to be in hand before your first shipment of that year. Four months of statutory processing time, plus the time it takes you to assemble the application, means the work belongs in 2027.

That is why the unsettled product list matters less than it looks. If your goods are anywhere near the categories above, the planning question — do we expect to cross 50 tonnes? — has to be answered before the list is final, because the clock is longer than the remaining legislative process.

The threshold arithmetic, and one honest gap

The 50-tonne de-minimis is defined in Regulation (EU) 2025/2083, recital 3, as a threshold based on the cumulative net mass of the imported goods in a calendar year per importer, applied across all covered sectors together — not per shipment, not per product type.

For downstream goods there is a question we have not been able to settle at primary text: whether that same net-mass basis carries over, or whether the relevant mass is only the metal content of the finished article. Secondary commentary suggests emissions would be attributed only to the precursor metal, which is a different question from how the threshold is measured, and the two get conflated easily.

The difference is not academic. At an average metal content around 79%, the two readings are about 27% apart in units. For a 70 kg washing machine that is roughly 714 units versus 1,190 to reach the same threshold. If you are near the line, that gap decides whether you are in scope.

We would rather tell you this is open than guess it. When the final text lands, it is one of the first things worth reading properly.

What is already clear is that 50 tonnes is a low bar for this class of goods. Downstream products are light and expensive per tonne compared with the coils and billets CBAM has covered so far — a steel coil alone weighs 25 to 30 tonnes, so two of them clear the threshold. Reaching 50 tonnes in fasteners, motors or appliances takes a lot more units, but it is an ordinary annual volume for a mid-sized manufacturer or distributor. Whoever crosses this line will tend to cross it narrowly, which is exactly the position where the answer is least obvious.

The quieter problem: nobody has done this before

Around 18,000 importers are in scope today (Commission staff working document SWD(2025) 58, Table 1). Most of them have been filing quarterly reports since 2023 and have somebody who knows what a CN code is.

The importers arriving in 2028 are a different population. A machinery builder importing motors has never filed a CBAM report, has no customs department, and in many cases has no idea the file exists. The extension does not make CBAM harder for people who already do it — it hands it to people who have never done it, with a first deadline that arrives before their first declaration.

If you are in that group, the advantage of finding out now is simply time. Nothing about this is technically difficult. It is administratively unforgiving.

What to do this year

1. Check your CN codes against the three draft lists, not just one. If your goods appear in any of them, plan as if you are in. Trilogue narrows and widens lists; it rarely removes an entire category that all three institutions put in.
2. Estimate your 2028 volume in net mass now, cumulatively across all CBAM goods you import — including anything already in scope today. The threshold is one number for everything, not one per product group.
3. If the answer is anywhere near 50 tonnes, start the authorisation in 2027. Not after the first shipment. The 120 days is a ceiling on the authority's side; your own preparation comes on top.
4. Ask your suppliers what emissions data they can produce — and by when. This is the item with the longest lead time and the one most likely to be outside your control.
5. Watch the Parliament vote this month. It sets the outer edge of the scope going into trilogue, and it is the last public signal before the text is negotiated behind closed doors.

What we would not do

We would not wait for the final text before estimating volumes. The estimate does not depend on the list being final — it depends on your own purchasing, which you already know. And we would not assume that a product missing from the Commission's original 180 is safe: the Council's annual review mandate means Annex I stops being a fixed list from 2028 onwards. Whatever is agreed is a starting point, not a settlement.

This article describes proposed legislation that has not been adopted. Product lists, thresholds and dates may change in trilogue. It is general information, not legal advice; for your own position, check the final text and speak to a qualified adviser.