Negotiators from the European Parliament and the Council met on 20 October 2026 for their first trilogue on COM(2025)989, the proposal that would push the carbon border mechanism further down the steel and aluminium value chain. They presented their mandates, reached no overall agreement, and reportedly set the next round for 30 November 2026. As of 23 October no EU institution had published a formal readout, so the sequence of the meeting rests on trade press reporting summarised by cbamguide.com and attributed there to Agence Europe.
For a company shipping screws, bolts, nuts or washers into the EU, the more consequential news is quieter. Those goods are not waiting on this file. CN heading 7318 has been inside the CBAM iron and steel scope from the start, and it has carried financial obligations since the definitive period began on 1 January 2026.
The scope question is settled, for 7318 at least
The Commission's own sector guidance for iron and steel, Guidance No. 5d, sets out in Table 2-1 the goods covered in the definitive period. The row for "iron or steel products" runs 7205, 7208 to 7217, 7219 to 7223, 7225 to 7229, 7301 to 7311, 7318 and 7326, and the description of 7318 reads "screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel". The Commission's published CBAM default values go further and price the heading subheading by subheading, with separate figures for coach screws, wood screws, screw hooks and rings, self-tapping screws, other screws and bolts, nuts, washers, rivets, cotters and spring washers. That table was issued for the transitional period, which closed on 31 December 2025, but it settles the classification question: the Commission has been treating 7318 goods as CBAM goods, at a granular level, since reporting began.
So the trilogue is not deciding whether a bolt is a CBAM good. It is deciding what comes after the bolt: the wire, springs and finished appliances that sit one or two processing steps further down, and how the emissions behind them are counted.
That distinction matters because it changes what a supplier should be doing this quarter. A fastener exporter does not need to wait for a final text before assembling emissions data. Its European customers already need that data, or will need it the moment their own imports cross the mass threshold.
What is already running
The definitive regime has been live since 1 January 2026 under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, which was published in the Official Journal on 17 October 2025 and has applied since 20 October 2025.
Imports of CBAM goods are exempt where an importer stays under a single mass-based threshold of 50 tonnes net mass per calendar year, counted cumulatively across iron and steel, aluminium, fertilisers and cement. Electricity and hydrogen get no such allowance. Above the threshold, the importer must hold authorised CBAM declarant status before importing, submits an annual declaration by 30 September covering the previous calendar year, and surrenders certificates against the embedded emissions declared. The first declaration falls due on 30 September 2027 for goods imported in 2026. Certificates go on sale from 1 February 2027, and from 1 January 2027 a declarant must hold certificates covering at least 50% of the emissions imported so far in the year.
The financial exposure ramps rather than bites at once. Free allocation under the EU ETS is phased out between 2026 and 2033, and only from 2034 are embedded emissions fully covered by certificates. That glide path is why some buyers are relaxed about 2026 shipments and why their finance teams are not.
Where the three institutions stand on going further
The extension itself is agreed in principle. All three institutions accept that downstream steel and aluminium goods should be covered from 1 January 2028. They disagree on how many goods that means.
The Commission's proposal of 17 December 2025 covers about 180 downstream products selected for high carbon leakage risk and a high share of steel or aluminium content, averaging 79% content by the Commission's own assessment. Parliament's research service describes the added goods as metal-intensive industrial, construction and electrical equipment products. The Council's general approach of 12 June 2026 added roughly 200 further CN codes to that list, among them heat pumps and industrial robots. Parliament went furthest: its negotiating mandate, adopted in plenary on 15 September 2026 by 464 votes to 50 with 159 abstentions, is built on a committee report that reaches 457 products.
Institution |
Instrument |
Date |
Reported scope |
European Commission |
Proposal COM(2025)989 |
17 Dec 2025 |
~180 downstream products, 79% average steel/aluminium content |
Council of the EU |
General approach |
12 Jun 2026 |
Commission list plus ~200 CN codes |
European Parliament |
First-reading mandate, 464–50–159 |
15 Sep 2026 |
~457 products (committee report figure) |
Trilogue |
First political trilogue |
20 Oct 2026 |
No overall agreement (press reports) |
The three counts are not three drafts of one annex. They are negotiating positions built on different selection criteria, and the gap between 180 and 457 is too wide to close by tidying the wording. Until a single text exists, no exporter can say with confidence which finished goods will carry CBAM obligations in 2028.
Four issues that went to technical work
The reports of the October meeting name four questions that were pushed down to working level rather than settled politically: the de minimis treatment of aluminium products and how the existing 50-tonne exemption applies to light finished goods; the treatment of metal scrap, including whether pre-consumer scrap counts as a precursor; whether goods sold through online platforms fall inside the regime; and the global default emission values to be applied to the goods being added.
Two of those four reach back into fastener supply chains. Default values decide the emissions figure an importer uses when verified installation data is unavailable, and on a product where value per tonne is low and tonnage is high, the default largely decides the landed cost. The scrap question decides whether the emissions already embedded in the steel input are counted once or twice, and pre-consumer scrap is a normal feedstock in fastener production rather than an exception.
The Parliament text also hardens the anti-circumvention language, defining resource shuffling and giving the Commission power to apply the true country of origin's default values where a pattern of circumvention is established. For a producer whose output goes to several regions, that puts a premium on being able to show consistent emissions intensity across the whole plant rather than a clean line kept for European buyers.
One point of confusion worth flagging
Parliament's own press release on the September vote describes the extended scope as reaching "finished steel and aluminium goods such as fasteners, wire, springs and household articles", which reads as though fasteners were about to be added. The legislative texts and the Commission's sector guidance point the other way for CN 7318, where coverage already exists. Wire under 7312 and springs are a different matter and are not in the current list.
The practical reading is that importers should check their own commodity codes against the CBAM annex rather than rely on summary wording in a press release, ours included. Classification is where the obligation actually attaches, and a good can move scope through a change of code as easily as through a change of law.
What does not change yet
Nothing in the downstream file alters an obligation that already exists. Until an amended regulation is adopted and published, the 2028 start date remains a proposal, and the end-2026 target for political agreement is an ambition rather than a deadline. A second trilogue reported for 30 November 2026 is the next point at which the product list is likely to start narrowing.
What an exporter can do without waiting is dull and useful: know the emissions figure per heat or per tonne for the steel going into each shipment, keep it attached to the mill documentation that already travels with the lot, and have it verifiable by an accredited body rather than self-declared. That work is identical whether the final list holds 180 goods or 457.
Shaanxi Flourish Industrial supplies hex bolts, studs, U-bolts, anchor bolts, nuts, washers, screws, flanges, spiral-wound gaskets and steel pipe fittings to North America, Western and Eastern Europe, East Asia, Southeast Asia, the Middle East and Africa. Our shipments carry EN 10204 3.1 and 3.2 material certificates, dimensional inspection reports and salt spray test results as standard, with hardness, tensile and yield testing in our own laboratory and SGS, BV or TÜV inspection available on request. We are tracking the CBAM downstream file and will set out the scope implications for fastener buyers once a final text is adopted. Buyers who need mill-level documentation to prepare a declaration can request it with their next order.
Sources. Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083 (published in the Official Journal on 17 October 2025, applicable since 20 October 2025); Commission Guidance Document No. 5d, Sector-specific guidance document on iron and steel, Table 2-1 (goods in scope for the definitive period, including CN 7318); Commission default values for CBAM goods, iron and steel section (7318 priced at subheading level); Commission proposal COM(2025)989 of 17 December 2025; Council general approach of 12 June 2026; European Parliament first-reading mandate, adopted 15 September 2026 by 464 votes to 50 with 159 abstentions (press release ref. 20260911IPR47450); European Parliamentary Research Service, "Extension of CBAM scope to downstream goods and anti-circumvention measures", PE 791.461, September 2026; European Commission answer to parliamentary question E-10-2026-002504, 25 August 2026 (proposed entry into force 1 January 2028, 180 downstream goods, Council adding 200 CN codes); summary of the CBAM Regulation on EUR-Lex (50-tonne single mass-based threshold, 30 September declaration deadline, certificate sale from 1 February 2027, quarterly 50% holding from 1 January 2027). The account of the 20 October 2026 trilogue, the four issues moved to technical level and the reported 30 November follow-up come from press reporting summarised by cbamguide.com on 23 October 2026, citing Agence Europe; no EU institution readout had been published at that date. Product-count figures are directional, not an adopted annex.
