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CBAM from 2028: Which industries and goods are likely to be next

From around 2028 onwards, attention is expected to shift towards downstream products – goods that incorporate CBAM‑covered materials but are further processed, manufactured or assembled. In this article we consider what this might mean and how businesses can prepare now.

Both the EU and UK have been clear that the Carbon Border Adjustment Mechanism (CBAM) is not intended to remain limited to a narrow set of basic materials. The initial focus on primary sectors such as steel, aluminium and cement is widely viewed as a starting point rather than the end point.

From around 2028 onwards, attention is expected to shift towards downstream products. For many businesses, this may be where CBAM becomes more visible and commercially significant.

What are downstream products?

Downstream products are goods that contain CBAM‑covered materials as inputs, but which are traded as finished or semi‑finished products rather than raw materials. Examples include manufactured components, fabricated parts and finished consumer or industrial goods.

The rationale for extending CBAM downstream is to reduce the risk of circumvention, where production shifts from raw materials to processed goods to avoid carbon costs, while ensuring carbon pricing is applied consistently across supply chains.

What industries are most likely to be affected by changes to CBAM?

Based on policy signals and existing CBAM design, downstream exposure is most likely to emerge first in sectors that make intensive use of steel, aluminium and cement. Construction products are widely expected to be an early focus. This could include fabricated structural steel, reinforcement products, metal frames, cladding systems and certain prefabricated construction components.

Manufacturing and engineering sectors may also see growing coverage. Items such as metal components, machinery parts, fasteners, pipes, tanks and engineered structures may come under increased scrutiny where their carbon content can be clearly linked to in‑scope materials.

The automotive, transport and machinery supply chains are another area of attention. While complete vehicles are unlikely to be brought into scope initially, specific parts or assemblies with high steel or aluminium intensity could be considered over time. Articles such as engine parts, car components, and vehicle additional parts are all likely to be affected.

Consumer and industrial goods using aluminium, such as packaging, household products and electrical enclosures, may also be captured in later phases as CBAM methodologies mature. This could also involve washing machines, dishwashers and tumble dryers.

It is possible that plastics and ceramics will also be included.

What could these CBAM changes look like in practice?

Rather than an immediate expansion to all manufactured goods, CBAM is more likely to extend gradually. This may involve the inclusion of specific product categories, thresholds based on material content, or targeted lists of high‑risk downstream goods. Reporting requirements may also evolve before financial charges are applied, giving regulators better visibility of carbon exposure across downstream supply chains.

Why do future CBAM changes matter now?

For businesses that do not currently trade in basic materials, downstream expansion represents a shift in where CBAM risk sits. Companies that have not previously considered emissions data may start receiving requests from customers or authorities as supply chains become more transparent. Early awareness allows businesses to assess exposure, engage with suppliers and avoid being caught by surprise as CBAM scope evolves. Even if you think you are not affected now, you could be in 2028.

How can I prepare for future CBAM expansion?

While no final decisions have been made on downstream scope, the overall direction of travel is clear. Carbon intensity is increasingly influencing trade policy, and downstream products are part of that trajectory. Businesses that understand the materials within their products, and how those materials are sourced and manufactured, will be better positioned to respond as CBAM develops beyond its initial phase.

  • Identify whether your products contain significant amounts of CBAM‑covered materials such as steel, aluminium or cement, even if you do not import those materials directly.

  • Map your supply chains to understand where carbon‑intensive inputs are sourced and whether emissions data may be required in the future.

  • Monitor policy developments closely from 2026 onwards, particularly consultations or reporting extensions relating to downstream goods.

Many businesses are already engaging with certified CBAM training or advisory providers to assess future exposure and build internal capability ahead of expected downstream expansion. Early preparation can reduce disruption if CBAM scope widens from 2028.

Do you need further help or advice?

Article reviewed by the InterTradeIreland Trade Hub Team: April 2026