Frankfurt, 17 December 2025 – Regarding the proposals presented today by the European Commission to extend the Carbon Border Adjustment Mechanism (CBAM), Holger Kunze, Director VDMA European Office, comments:

•    “Adding more products in the CBAM scope increases complexity, bureaucracy and costs for EU businesses contradicting the EU’s recent simplification efforts. This is the wrong signal for Europe’s machinery industry at a time of growing global trade tensions.”

•    “The Commission fails to recognise that extending the scope to further steel and aluminium-intensive downstream products , such as cranes and machinery parts, will only increase the cost and bureaucratic burden. This significantly increases the risk of production being relocated outside the EU.”

•    “The proposed legislation offers no export solutions for affected downstream sectors of the mechanical engineering industry. Higher export costs continue to weaken the competitiveness of our products on global markets, even though they make an important contribution to the energy transition.
  
•    “Likewise, the de minimis threshold must be raised to ensure that small and medium-sized enterprises remain exempt from the scope of CBAM.” The

VDMA represents 3600 German and European mechanical and plant engineering companies. The industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany. In the European Union, it represents a turnover volume of an estimated 870 billion euros. 

Around 80 percent of the machinery sold in the EU comes from a manufacturing plant in the domestic market.