This was an invitation-only event.
As the EU moved into the definitive phase of the CBAM, a major legislative package has been delivered in Q4 2025, covering 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 provides the ERCST’s timely and comprehensive response to the European Commission’s forthcoming proposal. It offers a detailed analysis and critical reflection on those key design questions, and offer recommendations.
This closed stakeholder consultation brought together a wider group of stakeholders to examine the proposal once more during ERCST’s drafting of the report. 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.

