As the EU moves into the definitive phase of the CBAM, a major legislative package is expected 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 will provide the ERCST’s timely and comprehensive response to the European Commission’s forthcoming proposal. It will offer a detailed analysis and critical reflection on those key design questions, and offer recommendations.

At this event the ERCST will launch and present a paper and open the floor for feedback. Discussion will centre 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.