Over May and June 2026, CBAM continued to evolve from a reporting obligation into a broader strategic requirement for companies trading with the European Union. The most important development came in June 2026, when the Council of the European Union agreed its position on strengthening the Carbon Border Adjustment Mechanism, confirming the planned extension to selected downstream products, introducing stronger anti-circumvention measures, and reinforcing the EU's long-term ambition to integrate carbon accounting deeper into international supply chains. For importers and manufacturers, the message is clear: CBAM is becoming a structural business factor that will influence sourcing decisions, supplier relationships, and competitiveness in the European market.
1. EU Moves Forward With CBAM Expansion to Downstream Products
In June 2026, the Council of the European Union agreed its position on strengthening CBAM, including the planned extension of the mechanism to selected downstream products that contain significant amounts of CBAM-covered materials, particularly products linked to iron, steel, and aluminium.1
Until now, CBAM has mainly focused on raw materials such as steel, aluminium, cement, fertilisers, electricity, and hydrogen. However, the EU identified a growing risk that carbon-intensive production could move further down the value chain, allowing processed goods to enter the EU market without reflecting their embedded emissions. The proposed expansion aims to address this by extending CBAM coverage to products where embedded emissions remain significant.1
For companies importing manufactured goods, components, or products containing CBAM materials, this means that future compliance requirements may increasingly depend on visibility across the entire supply chain.
2. Stronger Anti-Circumvention Measures Increase Compliance Pressure
Alongside the expansion of CBAM's scope, the EU is strengthening measures to prevent companies from avoiding CBAM obligations. The proposed framework introduces additional safeguards against practices such as changing product classifications, restructuring supply chains, or using approaches that could reduce reported embedded emissions without actual reductions in carbon intensity.2
The European Commission considers these measures necessary to protect the effectiveness of CBAM and prevent carbon leakage.2
For businesses, this means CBAM is moving beyond a customs-related requirement. It is becoming a system that requires reliable emissions data, transparent supply chains, and stronger cooperation with suppliers outside the EU.
3. CBAM Moves Toward Full Value-Chain Carbon Accounting
The latest developments reinforce a broader trend: the EU is moving from carbon reporting on individual materials toward carbon accounting across complete product chains. As CBAM expands, companies will increasingly need insight into:3
- production locations;
- raw material origins;
- manufacturing emissions;
- supplier-provided carbon data;
- verification processes.
This will create new operational challenges, especially for companies working with international suppliers where emissions data is not always readily available. Companies that start preparing their data processes now will be better positioned as CBAM requirements continue to expand.
4. CBAM Increasingly Impacts Global Competitiveness
CBAM is becoming an important factor in international trade discussions. Exporters outside Europe are facing increasing pressure to reduce emissions intensity in order to remain competitive in the EU market. Industries linked to steel, aluminium, and manufactured goods are expected to experience the strongest impact, particularly where production processes rely on carbon-intensive energy sources.4
The introduction and expansion of CBAM also reinforces a wider trend: carbon emissions are becoming a direct economic factor in global trade. Companies investing in lower-emission production methods and reliable carbon reporting systems may gain a competitive advantage, while companies relying on high-emission processes may face increasing costs when exporting to the EU.4
5. Outlook: CBAM Becomes a Permanent Business Consideration
The developments of the past two months reinforce three key CBAM trends:
- Broader coverage — CBAM is expanding beyond raw materials toward selected downstream products, increasing the number of companies potentially affected.1
- Stricter enforcement — the EU is strengthening measures to ensure imported products reflect their true carbon impact.2
- Greater strategic importance — carbon emissions are becoming a factor in pricing, procurement, sourcing decisions, and international competitiveness.4
For companies trading with the EU, CBAM should no longer be viewed as a future compliance topic. It is becoming a permanent part of doing business in the European market. Businesses that build reliable emissions data processes and prepare their supply chains early will be best positioned for the next phase of CBAM.
In collaboration with
Hulsman & Partners
This article was produced in collaboration with Hulsman & Partners. Looking for expert guidance on CBAM compliance? Their team offers specialised consultancy to help your organisation navigate the Carbon Border Adjustment Mechanism.
Visit Hulsman & PartnersSources
- European Council — Council moves to strengthen the EU's Carbon Border Adjustment Mechanism (June 2026)
- European Commission — Commission welcomes Council agreement on strengthening CBAM (June 2026)
- European Commission — Carbon Border Adjustment Mechanism overview
- Reuters — EU to strengthen carbon levy on high-emission imports and crack down on attempts to dodge it (December 2025)