The European Commission has put forward a plan to extend CBAM to downstream products containing significant steel or aluminium content starting in 2028. The initial coverage would include 180 product categories. The European Parliament supports a wider scope, while the Council has proposed its own adjustments. As of 12 October 2026, the additions are still under negotiation and do not create current import obligations.
Downstream products and the status of proposed CBAM changes
The proposed expansion would move carbon-related considerations beyond the commodities already covered under the mechanism. It would apply to selected finished products rather than limiting requirements to steel and aluminium commodities. Turkish exporters supplying goods that may fall within the expanded categories could be affected. The extent of exposure depends on the outcome of negotiations and final product classifications.
Supply chains serving EU manufacturing centres
The potential impact is concentrated in supply chains linked to Germany, Italy and other EU manufacturing centres. Turkish firms supply metal mountings, fabricated products, engineering components and machinery-related goods. These items may incorporate steel or aluminium produced at separate industrial installations. Under an expanded framework, importers may need to connect finished components with their metal precursors, relevant manufacturing processes and information provided to EU customers.
Türkiye’s export position is supported by relatively short freight times to European markets, established customer relationships, production flexibility and product customisation. At the same time, pressure has already been present in basic steel competitiveness. EUROFER reported a 16% year-on-year decline in Turkish finished-steel shipments in the first half of 2026. Despite the decline, Türkiye remained the EU’s largest supplier by volume share, accounting for 15.7% of finished-steel imports.
Why embedded emissions data may be harder to generalise
A single national emissions factor would not be sufficient to assess potential carbon exposure for every Turkish manufacturer under an expanded approach. Steel production can involve different furnace routes, while aluminium can be produced through primary or secondary processes, leading to different emissions profiles. In addition, a fabricator’s electricity consumption alone does not determine the embedded emissions of purchased metal. Installation information and precursor data would need to be documented using methods applicable under the final rules.
For Turkish exporters, access to upstream production records could become part of maintaining European customer relationships. Companies able to identify material origin and provide reliable emissions information may be better placed to respond to buyer requests as negotiations progress. This includes situations where compliance expectations evolve ahead of formal entry into force for any adopted legislation.
Contract provisions, procurement decisions and sourcing strategy
Commercial arrangements could change before any new rules take effect. European manufacturers could seek contractual provisions that allow them to request emissions records and obtain audited material declarations. They may also renegotiate prices if regulatory requirements change. Turkish suppliers that provide requested information promptly could improve their position in procurement decisions.
The proposal also raises questions about investment and sourcing strategy for Turkish industry. Manufacturers securing verified lower-emission steel or aluminium may be positioned to negotiate longer-term supply agreements with selected mills while preserving existing European contracts. If EU buyers demand price reductions tied to anticipated carbon-related costs, processors with limited margins could face additional commercial pressure. These shifts could occur even before a specific finished product becomes subject to a CBAM certificate obligation.
Negotiations in Brussels and implications for documentation
The eventual impact will depend on negotiations in Brussels, final product classifications and the capacity of Turkish industry to organise and verify upstream emissions data. Until rules are adopted, exporters and importers are expected to distinguish potential future exposure from obligations already in force. Türkiye’s geographic proximity to Europe and established industrial links remain relevant competitive advantages for market access.
Under a broader CBAM framework, logistics and pricing may not be sufficient on their own for determining supply attractiveness in European procurement. Material traceability, emissions documentation and the ability to substantiate production data could become increasingly important factors for buyers evaluating potential suppliers.