The latest CBAM draft expands the scope of the mechanism to finished and semi-finished steel and aluminium products. The change formalizes a shift in how carbon pricing connects to manufacturing value chains, linking cost, risk, and compliance to electricity-related factors. EU coverage is described as extending beyond factory-level emissions to include electricity sourcing, pricing, and carbon intensity.
Electricity is presented as both a direct input and a system-level constraint for multiple industrial segments. Steel tube producers, machinery assemblers, and fastener manufacturers are described as operating within power systems shaped by fuel markets, cross-border flows, balancing constraints, and fluctuating renewable output. The downstream linkage is described as making carbon intensity a systemic concern rather than a factory-specific metric.
CBAM coverage shifts from embedded carbon to electricity-linked emissions
Under the original CBAM framework, compliance focused on embedded carbon in slabs, billets, or aluminium ingots relative to EU benchmarks. The expanded approach broadens the focus to how carbon-intensive the electricity is that powers rolling mills, extrusion presses, CNC lines, galvanising baths, or assembly cells. Electricity is described as the channel through which CBAM costs propagate across hundreds of product categories previously outside climate policy.
This approach is framed around electricity use within production steps rather than only upstream material inputs. Rolling mills and extrusion presses are cited as examples of equipment where electricity carbon intensity becomes part of the compliance context. Assembly cells and galvanising baths are also included among the operations referenced in the expanded scope.
South-East Europe faces structural exposure from power system characteristics
The effect is described as particularly pronounced in South-East Europe and neighbouring regions. Manufacturing in Serbia, Bosnia and Herzegovina, North Macedonia, Ukraine, and

