On 7 October 2026 Mayer Brown published a legal update on the European Union’s proposal to extend the Carbon Border Adjustment Mechanism to downstream steel and aluminium goods. The firm wrote that technical talks among the Commission, the Council and Parliament had already begun, and that the first political trilogue is scheduled for 20 October 2026 during the European Parliament’s Strasbourg sitting. A second meeting is provisionally set for 30 November. The co-legislators are aiming for a political agreement before the end of 2026.
The file is 2025/0419(COD), based on Commission proposal COM(2025) 989 of 17 December 2025. Parliament adopted its negotiating mandate on 15 September by 464 votes to 50, with 159 abstentions. The Council agreed its general approach on 12 June. Parliament’s legislative-train note, last updated on 20 September, already recorded the file as being in trilogue. None of those texts is adopted law. The mechanism in force is still Regulation (EU) 2023/956. Ferrous waste and scrap under CN 7204 and aluminium waste and scrap under CN 7602 still do not require CBAM certificates. See CBAM and scrap metal and Parliament’s 15 September vote.
What the 20 October meeting has to settle
The Commission would add about 180 downstream product types from 1 January 2028, mainly steel- and aluminium-intensive articles such as fasteners, wire, tubes and metal furniture. The Council’s mandate is close to that list, at about 200 types. Parliament’s mandate goes further, to about 457 types. Those figures come from the same Mayer Brown comparison. They matter to fabricators and importers of finished metal goods. Growth of that list does not put a carbon certificate on a cargo of HMS or used beverage cans.
The scrap question inside the same file is the precursor list: whether metal scrap consumed in making a CBAM good carries embedded emissions into that good. The Commission and the Council keep pre-consumer steel and aluminium scrap on that list and leave post-consumer scrap out. The Council’s June text says a claim that material is post-consumer scrap should be backed by evidence of origin, and that without that evidence the material is treated as pre-consumer. Parliament’s mandate moves the two metals in opposite directions. On aluminium it would count all waste and scrap under CN 7602, including post-consumer scrap, as a precursor, and apply a single default value to unwrought aluminium whatever the scrap share. On steel it would require emissions from pre-consumer steel scrap to be reported but would not count them toward embedded emissions.
That split is the part of the 20 October meeting that yards and remelters can actually use. A scrap-fed electric-arc melt and a scrap-fed aluminium remelt would not face the same precursor rule if Parliament’s line survived. The final regulation will match none of the three texts exactly.
Who it affects among yards, traders, mills and processors
European electric-arc mills and stainless works remain the intended industrial beneficiaries of a longer downstream list, as Eurofer said after the 15 September vote. If imported fabricated articles pick up a carbon charge closer to EU ETS costs, more of those goods have a reason to be finished from metal melted in the Union. That melt is often scrap-based. The precursor fight decides how clean that melt looks on a CBAM declaration, not whether a North Sea cargo of shredded scrap needs a certificate this month.
Aluminium remelters are more exposed on the precursor line than steel. If Parliament’s aluminium wording survives, EU customers of unwrought aluminium will need to know the scrap share and whether it is post-consumer. Yards that sell baled used beverage cans, new extrusions, mixed castings or fragmentiser aluminium already know those grades as Taldon, Tata, Tense and Twitch. What would be new is a paper trail that those lots are obsolete cans or factory offcuts, not a new grade name.
Steel yards selling HMS or shredded into an EU melt may be asked the same obsolete-versus-arising question even if steel scrap stays out of the emissions calculation. The Commission and the Council would still count pre-consumer steel scrap as a precursor. Do not price a parcel on a treatment that exists only in a mandate.
Traders booking seaborne ferrous or aluminium for Turkey, India or other third-country melts should keep this file separate from the waste-shipment list. Covered metal entering the Union is what CBAM prices. Whether a waste-classified lot may leave for a non-OECD port after 21 May 2027 is decided by the authorised-country list. The Commission consultation on that draft remains open until 16 October. See why the EU wants to limit scrap metal exports and end-of-waste scrap.
How to name the lot
Name the grade the furnace already charges, the tonnes, and the city or load port. If an EU mill or a fabricator that exports CBAM goods asks whether the arising is post-consumer obsolete scrap or pre-consumer offcuts, answer if you know and keep that distinction on the ticket. State whether the material is waste or claimed as end-of-waste. Do not write a CBAM saving, a precursor code or “post-consumer” as a marketing line on a mixed bag.
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