European Commission's Call for evidence and Public consultation on extending CBAM to downstream products (open until 26 August 2025)
Dear representatives of ARGE’s members,
The EU Carbon Boarder Adjustment Mechanism (CBAM) was the main topic at the ARGE Members’ Online Working Meeting held in June 2025 (two sessions). Within short you will receive the respective summary. At this meeting the question was addressed whether ARGE should engage in getting certain building hardware included in CBAM as ‘downstream products’. The outcome was to come to a conclusion on this matter at an ARGE Members’ Online Working Meeting to be held in November 2025 (date and time still to be defined). Prior to this meeting in November, we will address CBAM at the ARGE Conference 2025 in Portugal on 11th & 12th September and will also run a webinar on this topic in October.
This email is to bring to your attention, in case you are not yet aware, that on 1st July 2025 the European Commission opened a Call for evidence and Public consultation on the matter of extending CBAM to downstream products. Contributions can be made until 26th August 2025. This is the link to both the Call for evidence and the Public consultation: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions
With this Call for evidence and Public consultation the European Commission wants to hear the views of the stakeholders concerned. Business associations, companies, academic/research institution, other stakeholders and even private persons (EU citizens) can provide their contributions.
1. Call for evidence:
In the Call for evidence one can express one’s view on extending CBAM to downstream products in a brief and informal way. When opening the website for which the link is given above, the following can be seen on the landing page:
ARGE’s French member association, Union nationale des industries de la quincaillerie (UNIQ) has given its feedback already and ARGE will still do so.
2. Public consultation:
The Public consultation consists of a questionnaire in which questions are asked in respect to a potential impact of extending CBAM to downstream products. These questions are general and not product-specific. It is not asked whether one wishes or supports the inclusion of downstream products or opposes it. The European Commission's objective is to obtain information about expected impacts. Please note that one must register the association or company in EU’s Transparency Register before one can complete the questionnaire. When opening the website for which the link is given above, the following can be seen on the landing page:
ARGE and ARGE’s French member association, Union nationale des industries de la quincaillerie (UNIQ) have responded to the questionnaire already. Please find ARGE’s response attached (two pdf documents).
Since the responses provided in the questionnaire will be statistically evaluated, the more national associations and companies participate in the Public consultation, the better the views of a particular industry will be represented.
Engagement of our industry in the Call for evidence and the Public consultation:
@ National Associations (Full Members): ARGE encourages you to take part in the Call for evidence and Public consultation and to invite your members to do so as well. Please feel free to forward this email including the attachments to them.
@ Sobinco and IPA Beslag (Affiliated Members): It goes without saying that also your contributions will be welcome.
For your convenience, I have enclosed the slide deck depicting the input and the decisions taken at the ARGE Members’ Online Working Meeting on CBAM on 22nd & 25th November 2024. The input for this ARGE Members’ Online Working Meeting contains a comprehensive outline of CBAM and the option of extending CBAM to downstream products.
In case of any queries, please don’t hesitate to get back to me.
Kind regards
Hans
Hans Weissenböck
General Secretary
phone: +43 1 9795 109
mobile: +43 664 4004 053
EU Transparency Register ID number: 881365536049-72