Refrain from artificially adjusting supply chains so that goods qualify for lower default values; doing so is circumvention.

Importers, declarants and operators in CBAM supply chains must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

It is Art. 1(16), adding point (c) to Art. 27(2) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
The act gives its timing as: from entry into force (third day after publication), Art. 2. as of 2026-08-14
It names 4 industries by name: Steel, Aluminium, Cement and Chemicals. as of 2026-08-14
Compliance is checked by competent authority, n/a. as of 2026-08-14

Addressee Importers, declarants and operators in CBAM supply chainsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(16), adding point (c) to Art. 27(2) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor

Trigger

alteration of a supply chain whose purpose is to obtain lower default values

Obligation

Refrain from artificially adjusting supply chains so that goods qualify for lower default values; doing so is circumvention.

Who is affected

Addressee

Importers, declarants and operators in CBAM supply chains

Class

Businesses

Sectors

Names Steel, Aluminium and metals, Cement and concrete, Chemicals and refining

Applies

from entry into force (third day after publication), Art. 2

Burden drivers

D6 — 1 of 7 marks fire on this provision.

Source text

Verbatim

‘(c) artificially adjusting the supply chains to make the goods benefit from lower default values.

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