JBCE published its position paper on the proposed extension of the CBAM scope to downstream goods

22/06/2026

On 22 June 2026, JBCE published its position paper on the proposed extension of the CBAM scope to downstream goods, in the context of the Commission’s proposal.

JBCE welcomes the constructive elements of the proposal, but considers that significant concerns remain as to the proportionality and administrative feasibility of the proposed scope extension.

Key messages:

• Extending CBAM to downstream goods raises significant concerns as to proportionality and administrative feasibility, since the compliance costs imposed on importers would be disproportionate to the resulting reductions in emissions. JBCE calls for a careful review of the proposed scope and for the exclusion of items lacking proportionality or practical feasibility.
• Even if the downstream extension proceeds, the two simplification measures already incorporated in the proposal, namely the non-application of the mark-up on certain downstream goods and the precursor-based calculation principle, must be retained. Further simplification measures are nevertheless required to make compliance practical for importers.
• Even if the downstream extension proceeds, the proposed date of application (1 January 2028) is premature in light of the limited operational track record of the CBAM definitive period, the pending implementing and delegated acts, and the available verification capacity. JBCE calls for the date of application to be postponed, and for the adoption of the relevant implementing and delegated acts in a timely manner.
• The scope of supply chain practices captured by the proposal’s anti-circumvention provisions is not defined with sufficient clarity, undermining operators’ predictability. JBCE calls for that scope to be clarified.

JBCE remains committed to supporting an effective, proportionate and WTO-consistent implementation of CBAM, and stands ready to continue its dialogue with the European Commission, the European Parliament and the Council as the legislative process moves forward.

Kaori Tamamushi

Trade Policy

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Download documents: JBCE position paper on the proposed CBAM scope extension to downstream goods