Apply the complex-goods calculation counting precursors from both Annex I and the new Annex VIII, excluding those from exempted third countries.

Operators of installations producing complex CBAM goods 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(22); Annex II, point (2) replacing point 3 of Annex IV 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: applies from 1 January 2028 per Art. 2. as of 2026-08-14
It names 2 industries by name: Steel and Aluminium. as of 2026-08-14
Compliance is checked by accredited third party, annual. as of 2026-08-14

Addressee Operators of installations producing complex CBAM goodsAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(22); Annex II, point (2) replacing point 3 of Annex IV of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor

Trigger

determination of specific actual embedded emissions of complex goods

Obligation

Apply the complex-goods calculation counting precursors from both Annex I and the new Annex VIII, excluding those from exempted third countries.

Who is affected

Addressee

Operators of installations producing complex CBAM goods

Class

Businesses

Sectors

Names Steel, Aluminium and metals

Applies

applies from 1 January 2028 per Art. 2

Burden drivers

D4 · D2 — 2 of 7 marks fire on this provision.

Source text

Verbatim

Only input materials (precursors) listed in Annex I and Annex VIII and originating in third countries and territories that are not exempted pursuant to Annex III, Section 1 are to be considered.

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