CBAM downstream products: current scope vs 2028 proposal

Snippet answer: the CN code controls

For EU CBAM, a product's commercial label is not the scope test. Current scope follows the CN code and description in the current Annex I of Regulation (EU) 2023/956. A buyer should therefore start with the customs classification record, not with whether a part feels upstream or downstream.

COM(2025)989 proposes extending CBAM to selected additional downstream products from 1 January 2028, but the proposal is still in procedure 2025/0419(COD). A product that appears only in the proposal is a proposal watch item, not a current CBAM good.

Current downstream-looking goods already exist in Annex I

The current Annex I already includes some goods that many buyers would think of as finished or downstream articles. CN 7318 covers screws, bolts, nuts, washers and similar articles of iron or steel. CN 7326 covers other articles of iron or steel. CN 7616 covers other articles of aluminium.

Those examples do not mean every automotive component, machinery input, replacement part, or assembly is currently covered. They show why a buyer needs the exact CN code and description. A steel fastener can be current-scope while a different finished component may need a separate CN-code check.

Proposal-stage additions stay out of current-scope recordsProposal — not law

COM(2025)989 is the Commission's downstream-expansion and anti-circumvention proposal. Its legislative file is 2025/0419(COD), and the proposed downstream application date is 1 January 2028.

The proposal has not been adopted. Until a final act is adopted, published, and reviewed, proposed product rows should be held outside current-scope calculations and labelled as proposal watch items.

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.

Buyer examples: separate current, proposed, and unknown

A useful buyer table has three states: current Annex I match, proposal watch item, and not determined because the CN code has not been checked. That is more useful than a single yes/no column because downstream products can sit in any of those states depending on the code.

Use examples carefully. A steel bolt under CN 7318 is already anchored in current Annex I. An aluminium bracket classified under CN 7616 may need current-scope review. An automotive assembly or machinery input needs its own classification path before anyone can label it current, proposed, or outside current scope.

• Current row: exact CN code is printed in current Annex I and should move into the supplier-data workflow.
• Proposal row: exact CN code appears only in the COM(2025)989 proposal and should be monitored separately.
• Unknown row: product description exists, but the customs classification or Annex I match has not been reviewed.
• Outside-current row: checked CN code is not in the current Annex I; still keep source date and reviewer context.

Automotive components and machinery inputs need classification discipline

Social posts often frame the issue as raw materials being covered while finished automotive components or machinery inputs escape the mechanism. That phrasing can reveal buyer confusion, but it is not a scope rule. The official route remains CN-code matching against current Annex I and, separately, proposal monitoring.

For procurement, the safer workflow is to record the part description, supplier, CN code used in customs records, material context, current Annex I status, proposal status, and source date. Do not ask suppliers for full emissions data until the current-scope or monitored-proposal reason is clear.

Anti-circumvention is authority work, not a product scoreProposal — not law

COM(2025)989 also proposes stronger provisions around misclassification and under-declaration of goods, misdeclaration of emission intensities, and abusive practices. Those proposal provisions should be read from the official text and procedure record.

CBAM Pulse does not score circumvention, infer intent, or decide how an authority would treat a transaction. It can help keep product classification, declared goods data, supplier evidence, and proposal status visible for review.

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.

Practical workflow for a buyer

Start with the exact CN code used or expected in the customs record. Check the current Annex I first. If the code is current-scope, route it into the supplier request, evidence checklist, cost-planning, and preparation-pack workflow. If the code appears only in the proposal, keep it in a monitored proposal list.

The workflow should also preserve the review date. Current Annex I scope, proposal status, and product descriptions can change through official amendments, so the source date is part of the record.

• Check CN code and current Annex I status.
• Separate current rows from proposal watch items before supplier requests.
• For current rows, collect supplier and installation data with evidence references.
• For proposal rows, monitor the official procedure without changing current tools or assumptions.

How CBAM Pulse fits the downstream question

CBAM Pulse keeps the current goods checker tied to the reviewed current-scope snapshot. Proposal rows stay labelled as proposal material and do not silently enter current-scope results before adoption and source review.

That means a buyer can use CBAM Pulse to organise scope checks, supplier requests, evidence references, updates, and preparation packs while keeping current law and proposal monitoring separate.