The European Association of Automotive Suppliers (CLEPA) has called on the European Commission to address implementation challenges within the Carbon Border Adjustment Mechanism (CBAM) before extending the system to additional downstream products, particularly steel- and aluminum-containing goods.
According to the association, the transition from CBAM’s transitional phase to full implementation carries significant implications for automotive suppliers, whose operations depend heavily on global supply chains and imported steel, aluminum, semi-finished materials and components. It stated that the absence of default values and primary emissions data for newly proposed Combined Nomenclature (CN) codes makes it difficult for companies to assess the operational and financial impact of a broader CBAM scope.
Industry highlights unresolved compliance challenges
The association said experience gained during the transitional phase has exposed several unresolved issues, including limited access to reliable primary emissions data, incomplete default-value coverage, traceability limitations, legal uncertainty and substantial administrative burdens. Manufacturers often have limited influence over suppliers and sub-suppliers while remaining responsible for reporting obligations and potential penalties when emissions information cannot be obtained.
The association also pointed to concerns regarding China’s Regulations on Industrial and Supply Chain Security, which may restrict access to supply-chain information required for emissions reporting, ESG audits and CBAM compliance. CLEPA warned that such restrictions could force importers to rely on higher default emissions values, increasing costs even when imported products may have lower actual carbon intensity.
Calls for improved emissions data systems
To improve CBAM implementation, CLEPA proposed the creation of an EU-wide registry for primary emissions and Product Carbon Footprint (PCF) data. The association believes such a system would allow verified emissions information to be securely shared throughout supply chains while improving reporting accuracy.
CLEPA also called for a more balanced distribution of reporting responsibilities between importers and suppliers, clearer recognition of carbon costs already paid in third countries and full interoperability between the EU and UK CBAM and emissions trading systems. Regarding default emissions values, the association emphasized the need for comprehensive coverage across all CBAM products and any newly added CN codes. It argued that delays in publishing default values create uncertainty and complicate compliance planning.
Opposition to stricter default-value penalties
While acknowledging the role of default values in encouraging the use of primary emissions data, CLEPA stated that existing default values often overestimate emissions and fail to recognize investments in lower-carbon production methods.
The association opposed proposals to introduce additional mark-ups on default values, arguing that companies already face conservative emissions assumptions when primary data are unavailable. According to CLEPA, further mark-ups would increase compliance costs without improving either reporting quality or environmental performance.
Cautious approach to downstream CBAM expansion
On the proposed expansion of CBAM to downstream products, CLEPA stressed that any extension should be based on demonstrated carbon leakage risks and supported by detailed product-level analysis. The association said policymakers should consider the availability of EU-produced alternatives and ensure that any additional products brought into scope are also covered by the EU Emissions Trading System.
CLEPA further suggested reviewing the current 50-ton CO₂ de minimis threshold if CBAM is expanded and introducing an exemption threshold for low-volume imports, including prototype shipments, testing materials and other limited consignments.
Concerns over recycled materials treatment
The association also expressed concerns regarding proposals to include pre-consumer steel and aluminum scrap within CBAM. According to CLEPA, such measures could penalize companies that have invested in recycled-material supply chains and undermine broader circular economy objectives.
CLEPA concluded that CBAM remains an important tool for supporting EU climate goals and preventing carbon leakage. However, it argued that the immediate priority should be simplifying implementation, reducing administrative burdens and improving legal certainty before considering further scope expansion. The association stated that any future extension of CBAM should be gradual, evidence-based and operationally practical while supporting both decarbonization objectives and European industrial competitiveness.