The European Commission (EC) launched a public consultation to assess the potential extension of the Carbon Border Adjustment Mechanism (CBAM) to include downstream products.  This consultation explores additional anti-circumvention rules and improvements to the rules for electricity within the CBAM framework. 

This initiative responds to growing concerns about carbon leakage, wherein the production shifts to non-EU countries with less stringent climate regulations, or to EU buyers sourcing from such regions to reduce costs. The EC also aims to address these risks by potentially broadening CBAM’s coverage and introducing safeguards against unjustified circumvention practices. Stakeholders are invited to comment on the accuracy and fairness of default emission values and rules for electricity under the current system. 

The consultation is open to exporters, producers, trade associations, non-governmental organizations (NGOs), academic institutions and trade unions within or outside the EU. The insights will guide the Commission’s proposals as part of the broader European Steel and Metals Action Plan. 

Submissions are open until 26 August 2025. Stakeholders are strongly encouraged to participate via the Call for Evidence and Public Survey.  

For questions and clarifications, please contact Philippine Trade and Investment Center-Brussels at brussels@dti.gov.ph and/or the DTI-EMB Market Division at marketdivision@dti.gov.ph.