Inclusion of downstream products in CBAM

Abstract

The CBAM scope includes selected imported goods to ensure a level playing field with EU production covered by the EU ETS 1. While 573 mainly basic materials and products are covered, expanding the scope to downstream goods must be assessed. The paper identifies five criteria for prioritisation: share of CBAM inputs, emissions relevance, carbon-leakage risk, administrative burden, and avoidance of circumvention. It discusses how to operationalise and combine these criteria and provides examples, without giving a final recommendation. The aim is to define a framework that guides future CBAM scope expansion.