Proposed CBAM downstream expansion: what is official

Current scope has not changed

The current CBAM goods scope is the current Annex I of Regulation (EU) 2023/956, as amended. Importers should continue to check the CN code used in the customs declaration against that adopted annex.

A proposed downstream code must not be presented as a current CBAM good. CBAM Pulse keeps proposal material separate from its current-scope dataset and does not activate proposed product logic before adoption and source review.

What COM(2025)989 isProposal — not law

COM(2025)989 is a Commission proposal dated 17 December 2025. It is being considered through the ordinary legislative procedure under file 2025/0419(COD), so the European Parliament and the Council can amend it before any final act is adopted.

Its stated objectives are to extend CBAM to selected downstream goods and strengthen measures against practices that could unduly lower a CBAM liability. Publication by the Commission is the start of the legislative process, not the end of it.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

How the proposed downstream selection worksProposal — not law

The proposal's explanatory memorandum describes a balanced extension focused on downstream goods assessed as having carbon-leakage risk and high emissions intensity. The legislative annex carries the proposed CN-code changes and is the source to read for product-level detail.

This guide deliberately does not state a product-count headline. The reviewed official proposal supports the legal text and CN-code annex; unsupported counts reported elsewhere are not used as CBAM Pulse facts.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

The proposed application date is 1 January 2028Proposal — not law

COM(2025)989 proposes that the downstream extension and the related precursor changes apply from 1 January 2028. The explanatory memorandum says this timing is intended to provide predictability and allow the registry and other implementation work to be prepared.

That date remains proposed. It should not be entered as an adopted scope deadline unless a final act is published and its application provisions are verified.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

The proposal also addresses anti-circumventionProposal — not law

The Commission proposal responds to concerns about misclassification and under-declaration of goods, misdeclaration of emission intensities, and abusive practices that could undermine the mechanism. It proposes additional information, review, and enforcement provisions alongside the scope extension.

Anti-circumvention wording does not turn a preparation tool into an enforcement or risk-scoring system. Product classification, declared emissions, and any authority review remain matters for the official process and the competent authorities.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

Electricity changes sit in the same proposalProposal — not law

COM(2025)989 also proposes changes to the electricity emission-factor method and to the conditions for using actual emissions. Those provisions are separate from the downstream-goods question and are covered in the electricity guide.

Keeping those topics separate avoids implying that a proposed electricity methodology changes the current list of downstream goods, or vice versa.

This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.

What importers can do now

Continue screening imports against the adopted Annex I, retain the full CN codes used in customs records, and monitor the official legislative file for amendments and adoption. If a product appears only in the proposed annex, label it as a proposal watch item rather than a current obligation.

CBAM Pulse's goods checker reports the reviewed current-scope snapshot. It does not silently move proposed products into current results, and it does not make a customs-classification decision.