The Carbon Border Adjustment Mechanism (CBAM) has now been fully operational for six months. The European Commission now wants to extend it to processed products containing steel and aluminium, and the European Economic and Social Committee has backed the proposal with an almost unanimous vote. The extension will bring between 3,800 and 3,900 new SMEs into the mechanism's perimeter. What does it mean for Catalan industry?
A climate instrument coming of age
Since January 2026, CBAM has ceased to be a reporting exercise and become a fully operational mechanism: importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen must now buy and surrender CBAM certificates reflecting the embedded emissions of their products. In parallel, the EU is progressively phasing out free ETS allowances for the sectors covered. The logic is clear: if European producers stop receiving free allowances at the same rate as border protection rises, everyone pays the same carbon price and the incentive to relocate production outside Europe disappears.
This architecture, however, had an obvious gap: it did not cover already processed products. Nothing prevented importing steel and aluminium parts, components or semi-manufactures —products with a high carbon content— and thereby sidestepping the mechanism. This is what the technical literature calls downstream leakage.
Why the gap needs closing
The proposal COM(2025) 989 final amends Regulation (EU) 2023/956 to extend CBAM to processed goods containing steel and aluminium, and it introduces anti-circumvention measures. According to the Commission's impact assessment, the extension will reduce the risk of carbon leakage by approximately 25%.
The EESC Opinion C/2026/3243, adopted on 19 March with 220 votes in favour and none against, supports the extension but calls for attention to administrative proportionality and to consistency between the Combined Nomenclature codes included and excluded, in order to avoid new forms of circumvention.
3,900 new SMEs in the perimeter
The Commission estimates that the extension will subject between 3,800 and 3,900 new SMEs to reporting obligations. It is worth recalling that the Omnibus 1 package already raised the application threshold from 150 € to 50 tonnes per year, cutting the number of importers affected by 90% while still covering 99% of emissions. The EESC calls for consideration of a limited transitional period similar to that of the initial phase, for example requiring the purchase and surrender of 2028 CBAM certificates with a certain lag.
One relevant technical aspect: unlike the current CBAM, the 50-tonne threshold for processed products will apply to total weight, not only to steel and aluminium content. The EESC recommends that importers be able to demonstrate credibly that the content of these materials is below the threshold, so as to avoid disproportionate burdens.
The operational bottlenecks
Three issues will shape CBAM's next phase:
Availability of accredited verifiers. The shortage of verifiers is forcing the use of default values in many cases. The EESC calls for urgent measures to increase their supply and for those values not to be used punitively, especially for complex processed products (an industrial machine may incorporate thousands of parts).
Article 27a. This new clause would allow goods to be temporarily excluded from CBAM in serious and unforeseen circumstances. The EESC calls for transparent, predictable criteria and processes so that it does not create investment uncertainty, and for its activation to be accompanied by measures that continue to prevent carbon leakage.
The fertiliser question. The current fertiliser import crisis coincides with CBAM's full entry into operation. The Commission has already exempted fertilisers from certain import duties and removed the mark-ups on default values, but the EESC calls for a coordinated global approach together with the European fertiliser action plan to safeguard the 2026 and 2027 harvests.
The Achilles heel: exports
The Commission's package includes a temporary Decarbonisation Fund [COM(2025) 990 final] designed to support exporting industries as free allowances come to an end. The EESC is highly critical of it: it lasts only two years, covers few goods and is not aimed at exporting companies as such, but instead operates as a general subsidy to export-intensive sectors. What is needed, it says, is an export adjustment solution that is structural and compliant with WTO rules, together with the mobilisation of the future European Competitiveness Fund as the main instrument.
What it means for Catalan companies
The CBAM extension means preparing four things:
- Mapping of steel and aluminium content in the supply chain for processed products
- Systems for collecting embedded emissions data from non-EU suppliers, with the methodological discipline the regulation requires
- Preparation for accredited external verification, anticipating the current bottleneck
- Identification of funding opportunities in the temporary Decarbonisation Fund and in the future European Competitiveness Fund for low-carbon investment projects
For Catalan electro-intensive industry —steel, aluminium processing, ceramics, chemicals, cement, fertilisers— CBAM has ceased to be a background regulatory matter and become an operational variable affecting the supply chain, competitiveness and sourcing strategy. Companies that anticipate this transition will emerge stronger; those that do not will face the twin squeeze of internal carbon and border carbon.
How auma supports industry in the face of the MA
At auma we have spent more than thirty years advising industrial companies at the interface between environmental regulation, energy and competitiveness, and we support our clients in preparing for CBAM with a practical, sector-specific approach. We also help identify European and national funding opportunities for industrial decarbonisation projects that reduce CBAM exposure in the medium term. If your company is entering the mechanism's extended perimeter, or is already within it and wants to get ahead of the phase-out of free emission allowances,