Metal Packaging Europe (MPE) welcomes the European Commission’s proposals published on 17 December 2025 to strengthen and expand the Carbon Border Adjustment Mechanism (CBAM), marking an important step towards fairer carbon pricing, stronger climate ambition and greater industrial resilience for Europe. 

Under the Commission’s proposal, the scope of CBAM would be extended from 1 January 2028 to include downstream products with high steel and aluminium content. At present, while imports of primary steel and aluminium into the EU are subject to a CBAM charge, many semi-finished or finished products containing significant volumes of these materials remain outside the mechanism. This creates a clear risk of carbon leakage and undermines fair competition. 

In response, the Commission proposes extending CBAM coverage to certain downstream products such as can ends, classified under CN code 8309 90 90. MPE supports this inclusion as a necessary step to strengthen the mechanism. As CBAM enters its definitive phase, MPE considers that additional steel derivative products, including components such as crown corks, should be included to ensure comprehensive coverage and consistent treatment across downstream products. 

The proposed free allocation benchmarks are aligned with the EU Emissions Trading System and reflect the different climate impacts of primary and secondary production routes. This distinction is essential to recognise the lower carbon footprint of recycled steel and aluminium and to support circular production. 

MPE supports this step towards more proportionate carbon pricing for goods placed on the EU market. Differentiated benchmarks based on production routes help protect downstream value chains, support closed-loop recycling and avoid disadvantaging low-carbon manufacturing. 

“All industries that compete internationally and rely on CBAM materials must benefit from a clear and transparent regulatory framework that recognises downstream efforts towards circularity and decarbonisation,” said Krassimira Kazashka, CEO of MPE. “As CBAM enters its definitive phase on 1 January 2026, MPE welcomes the Commission’s efforts to ensure a balanced and effective implementation.”