A new 'Combined metal products' category enters CBAM scope, pulling downstream steel- and aluminium-containing manufactured goods into the embedded-emissions declaration and certificate-surrender regime for the first time.
Importers and authorised CBAM declarants of downstream steel- and aluminium-containing 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(21); Annex I, point (2) adding the 'Combined metal products' table to Annex I 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, per consignment. as of 2026-08-14
The rule
importation of goods listed in the new 'Combined metal products' table of Annex I
A new 'Combined metal products' category enters CBAM scope, pulling downstream steel- and aluminium-containing manufactured goods into the embedded-emissions declaration and certificate-surrender regime for the first time.
Who is affected
Burden drivers
Source text
‘[Combined metal products CN code Greenhouse gas 7314 31 00 – Other grill, netting and fencing, of iron or steel wire, welded at the intersection, plated or coated with zinc Carbon dioxide 7314 41 00 – Grill, netting and fencing, of iron or steel wire, not welded at the intersection, plated or coated with zinc Carbon dioxide 7314 49 00 – Grill, netting and fencing, of iron or steel wire, not welded at the intersection (excl. plated or coated with zinc or coated with plastics)
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