JBCE Position Paper on the CBAM Scope Extension to Downstream Goods

On 25 August 2025, JBCE published its position paper following the European Commission's call for evidence on the proposed extension of the scope of the Carbon Border Adjustment Mechanism (CBAM). 

JBCE raises three concerns regarding the extension of the scope, namely: 

• Lack of proportionality: Extending the scope to downstream goods may not be proportionate, considering that there are many small downstream goods with low embedded emissions.
• Difficulty in complying on the basis of actual emission data: It is extremely difficult to trace the actual embedded emissions in downstream goods, which involve numerous business operators in the upstream supply chain.
• Insufficient alternative measures to enable compliance: The application of the current default values designated by CN code and country of origin does not facilitate compliance, as downstream goods tend to be composed of numerous materials and components from multiple suppliers located in different countries.

In addition, JBCE believes that three elements need to be adjusted in parallel with the scope expansion.

• Provide options for downstream goods importers to adopt simplified methods to comply with CBAM with reduced administrative burden (e.g., single default value without mark-up).
• The threshold (50 tonnes of imports of CBAM-covered goods per year) could specify that only the net weight of parts made from CBAM-covered goods is taken into account when determining whether the threshold has been reached. This assessment could be based solely on self-assessment, which would not impose additional compliance burdens, such as third-party verification.
• Ensure, in the medium to long term, harmonisation between the carbon emissions calculation methodologies adopted in CBAM and Ecodesign for Sustainable Products Regulation (ESPR) regarding iron, steel and aluminium products.

For more information, please contact info@jbce.org