This was an invitation-only event.
As the EU moved into the definitive phase of the CBAM, a major legislative package was released in Q4 2025, covering the treatment of exports, the extension of CBAM to downstream sectors, and the EU’s anti-circumvention strategy.
This first report under the Border Carbon Adjustments in the EU – Phase VII workstream provided the ERCST’s timely and comprehensive response to the European Commission’s forthcoming proposal. It offered a detailed analysis and critical reflection on those key design questions, and offered recommendations.
This closed focus group meeting brought together a select group of stakeholders to examine the proposal in depth. Discussion centred on the Commission’s approach to exports, the planned downstream extension of CBAM, and the anti-circumvention framework, exploring the rationale behind these measures, their expected impacts, and remaining gaps in addressing identified risks.

