[{"data":1,"prerenderedAt":294},["ShallowReactive",2],{"blog:\u002Fblog\u002Fcbam-downstream-2028-deadline-2027":3},{"id":4,"title":5,"body":6,"date":279,"description":280,"extension":281,"hero":282,"heroAlt":282,"keywords":283,"meta":284,"navigation":285,"path":286,"readingMinutes":287,"seo":288,"stem":289,"tags":290,"__hash__":293},"blog\u002Fblog\u002Fcbam-downstream-2028-deadline-2027.md","CBAM's new product list isn't settled. Your deadline already is.",{"type":7,"value":8,"toc":268},"minimark",[9,18,25,30,41,52,63,66,80,84,95,98,105,109,119,122,147,153,160,164,171,178,189,192,199,203,210,213,216,220,253,257,260,263],[10,11,12,13,17],"p",{},"If you import gearboxes, fasteners, radiators or washing machines, there is a good chance CBAM\nwill apply to you from ",[14,15,16],"strong",{},"1 January 2028",". There is also a good chance nobody has told you,\nbecause the file is still moving and the trade press has been covering the politics rather than\nthe dates.",[10,19,20,21,24],{},"Here is the part that gets lost: ",[14,22,23],{},"the year that decides your position is 2027, not 2028."," That\nis true whatever the final product list looks like, and it is true even though the law has not\nbeen adopted yet.",[26,27,29],"h2",{"id":28},"where-the-file-actually-stands","Where the file actually stands",[10,31,32,33,36,37,40],{},"The Commission proposed the extension on ",[14,34,35],{},"17 December 2025"," (COM(2025) 989), covering ",[14,38,39],{},"180\ndownstream CN codes"," alongside a set of anti-circumvention measures.",[10,42,43,44,47,48,51],{},"The Council agreed its general approach on ",[14,45,46],{},"12 June 2026",". It refined the product list and — the\npart with the longest tail — instructed the Commission to ",[14,49,50],{},"review annually"," which further\ndownstream goods should be added.",[10,53,54,55,58,59,62],{},"Parliament's environment committee held an indicative vote on its position on ",[14,56,57],{},"6 July 2026",",\nwith adoption in plenary expected ",[14,60,61],{},"this month",". Reporting suggests Parliament wants to go\nfurther than the Council on scope. After that comes trilogue, with a final text expected late 2026\nor early 2027.",[10,64,65],{},"So there are three lists on the table and they do not match. We are not going to quote you a final\nnumber of product codes, because there isn't one yet, and every figure circulating today belongs\nto one institution's draft rather than to the law. Some of the counts being repeated are\nthemselves second-hand: the Council press release and several law-firm summaries are behind\naccess restrictions we could not read directly.",[10,67,68,71,72,75,76,79],{},[14,69,70],{},"What is not in dispute is the date."," All three positions apply the extension from ",[14,73,74],{},"1 January\n2028",", with the first declaration due ",[14,77,78],{},"30 September 2029",".",[26,81,83],{"id":82},"what-kind-of-goods-these-are","What kind of goods these are",[10,85,86,87,90,91,94],{},"According to the Commission's impact assessment, about ",[14,88,89],{},"94%"," of the affected downstream products\nare industrial supply-chain goods — inputs and components, not things on a shelf. Consumer\nhousehold products are roughly ",[14,92,93],{},"6%"," of the affected import volume.",[10,96,97],{},"The categories being discussed across the three positions are consistent even where the counts are\nnot: fabricated metal products, machinery and industrial equipment, vehicle components such as\ngearboxes and engines, domestic appliances such as washing machines and refrigerators, and metal\nconstruction equipment. Passenger cars themselves have been kept out.",[10,99,100,101,104],{},"The common thread is that these are ",[14,102,103],{},"steel- and aluminium-intensive manufactured goods",". This is\nnot CBAM branching into new materials. It is the same two metals, one processing step further\nalong, which is precisely the gap the anti-circumvention part of the proposal is meant to close:\ntoday you can import a finished component free of CBAM while the raw metal that went into it would\nhave been in scope.",[26,106,108],{"id":107},"why-the-deadline-lands-a-year-early","Why the deadline lands a year early",[10,110,111,112,115,116,79],{},"CBAM obligations do not begin when you file. They begin when you ",[14,113,114],{},"import",", and to import in\nscope you must already be an ",[14,117,118],{},"authorised CBAM declarant",[10,120,121],{},"Two provisions do the work here, and together they move the real deadline forward by a year:",[123,124,125,137],"ul",{},[126,127,128,131,132,136],"li",{},[14,129,130],{},"Article 5(1b)"," attaches the duty to apply to the ",[133,134,135],"em",{},"expectation"," of exceeding the threshold, not\nto the outcome. You are not permitted to wait, cross 50 tonnes, and then apply.",[126,138,139,142,143,146],{},[14,140,141],{},"Implementing Regulation (EU) 2025\u002F486, Article 4(1)"," gives the competent authority up to\n",[14,144,145],{},"120 days"," to decide on an application.",[10,148,149,150,79],{},"Put those together. If you expect to import more than 50 tonnes of newly-covered goods during\n2028, your authorisation has to be in hand before your first shipment of that year. Four months of\nstatutory processing time, plus the time it takes you to assemble the application, means the work\nbelongs in ",[14,151,152],{},"2027",[10,154,155,156,159],{},"That is why the unsettled product list matters less than it looks. If your goods are anywhere near\nthe categories above, the planning question — ",[133,157,158],{},"do we expect to cross 50 tonnes?"," — has to be\nanswered before the list is final, because the clock is longer than the remaining legislative\nprocess.",[26,161,163],{"id":162},"the-threshold-arithmetic-and-one-honest-gap","The threshold arithmetic, and one honest gap",[10,165,166,167,170],{},"The 50-tonne de-minimis is defined in Regulation (EU) 2025\u002F2083, recital 3, as a threshold based\non the ",[14,168,169],{},"cumulative net mass of the imported goods"," in a calendar year per importer, applied\nacross all covered sectors together — not per shipment, not per product type.",[10,172,173,174,177],{},"For downstream goods there is a question we have ",[14,175,176],{},"not"," been able to settle at primary text:\nwhether that same net-mass basis carries over, or whether the relevant mass is only the metal\ncontent of the finished article. Secondary commentary suggests emissions would be attributed only\nto the precursor metal, which is a different question from how the threshold is measured, and the\ntwo get conflated easily.",[10,179,180,181,184,185,188],{},"The difference is not academic. At an average metal content around 79%, the two readings are about\n27% apart in units. For a 70 kg washing machine that is roughly ",[14,182,183],{},"714 units"," versus ",[14,186,187],{},"1,190"," to\nreach the same threshold. If you are near the line, that gap decides whether you are in scope.",[10,190,191],{},"We would rather tell you this is open than guess it. When the final text lands, it is one of the\nfirst things worth reading properly.",[10,193,194,195,198],{},"What is already clear is that ",[14,196,197],{},"50 tonnes is a low bar for this class of goods",". Downstream\nproducts are light and expensive per tonne compared with the coils and billets CBAM has covered so\nfar — a steel coil alone weighs 25 to 30 tonnes, so two of them clear the threshold. Reaching 50\ntonnes in fasteners, motors or appliances takes a lot more units, but it is an ordinary annual\nvolume for a mid-sized manufacturer or distributor. Whoever crosses this line will tend to cross\nit narrowly, which is exactly the position where the answer is least obvious.",[26,200,202],{"id":201},"the-quieter-problem-nobody-has-done-this-before","The quieter problem: nobody has done this before",[10,204,205,206,209],{},"Around ",[14,207,208],{},"18,000 importers"," are in scope today (Commission staff working document SWD(2025) 58,\nTable 1). Most of them have been filing quarterly reports since 2023 and have somebody who knows\nwhat a CN code is.",[10,211,212],{},"The importers arriving in 2028 are a different population. A machinery builder importing motors has\nnever filed a CBAM report, has no customs department, and in many cases has no idea the file\nexists. The extension does not make CBAM harder for people who already do it — it hands it to\npeople who have never done it, with a first deadline that arrives before their first declaration.",[10,214,215],{},"If you are in that group, the advantage of finding out now is simply time. Nothing about this is\ntechnically difficult. It is administratively unforgiving.",[26,217,219],{"id":218},"what-to-do-this-year","What to do this year",[221,222,223,229,235,241,247],"ol",{},[126,224,225,228],{},[14,226,227],{},"Check your CN codes against the three draft lists, not just one."," If your goods appear in any\nof them, plan as if you are in. Trilogue narrows and widens lists; it rarely removes an entire\ncategory that all three institutions put in.",[126,230,231,234],{},[14,232,233],{},"Estimate your 2028 volume in net mass now",", cumulatively across all CBAM goods you import —\nincluding anything already in scope today. The threshold is one number for everything, not one\nper product group.",[126,236,237,240],{},[14,238,239],{},"If the answer is anywhere near 50 tonnes, start the authorisation in 2027."," Not after the\nfirst shipment. The 120 days is a ceiling on the authority's side; your own preparation comes on\ntop.",[126,242,243,246],{},[14,244,245],{},"Ask your suppliers what emissions data they can produce"," — and by when. This is the item with\nthe longest lead time and the one most likely to be outside your control.",[126,248,249,252],{},[14,250,251],{},"Watch the Parliament vote this month."," It sets the outer edge of the scope going into\ntrilogue, and it is the last public signal before the text is negotiated behind closed doors.",[26,254,256],{"id":255},"what-we-would-not-do","What we would not do",[10,258,259],{},"We would not wait for the final text before estimating volumes. The estimate does not depend on the\nlist being final — it depends on your own purchasing, which you already know. And we would not\nassume that a product missing from the Commission's original 180 is safe: the Council's annual\nreview mandate means Annex I stops being a fixed list from 2028 onwards. Whatever is agreed is a\nstarting point, not a settlement.",[261,262],"hr",{},[10,264,265],{},[133,266,267],{},"This article describes proposed legislation that has not been adopted. Product lists, thresholds\nand dates may change in trilogue. It is general information, not legal advice; for your own\nposition, check the final text and speak to a qualified adviser.",{"title":269,"searchDepth":270,"depth":270,"links":271},"",2,[272,273,274,275,276,277,278],{"id":28,"depth":270,"text":29},{"id":82,"depth":270,"text":83},{"id":107,"depth":270,"text":108},{"id":162,"depth":270,"text":163},{"id":201,"depth":270,"text":202},{"id":218,"depth":270,"text":219},{"id":255,"depth":270,"text":256},"2026-09-04","The extension to downstream goods applies on 1 January 2028, and three EU institutions still disagree on which products are in. None of that changes the year you have to act — because authorisation takes up to 120 days and has to exist before you cross the threshold.","md",null,"CBAM downstream extension, COM(2025) 989, CBAM 2028, CBAM machinery parts, CBAM fasteners, CBAM authorised declarant 120 days, CBAM 50 tonnes threshold, CBAM trilogue, CBAM anti-circumvention",{},true,"\u002Fblog\u002Fcbam-downstream-2028-deadline-2027",7,{"title":5,"description":280},"blog\u002Fcbam-downstream-2028-deadline-2027",[291,292],"compliance","deadlines","BJjeQPf_6vHBJ9_DmvS9ppTS5__S_F6VycGU3fKNe-I",1790002811016]