Joint High-Level Statement on the Extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream industries
4 May 2026
The signatories call on the European Parliament and Council to ensure an effective and broad extension of the CBAM to relevant steel and aluminium-intensive downstream industries.
While the CBAM represents a first attempt in addressing carbon leakage risks in upstream materials, its current scope is insufficient to ensure a level playing field across the full value chain. Downstream sectors, including energy, mobility, machinery, cookware, cutlery, catering equipment, packaging, construction, clean tech, defence, home appliances, hand tools and metal goods, are increasingly exposed to competition from imports of carbon-intensive finished products that fall outside the mechanism’s coverage. This creates a growing imbalance, as European manufacturers face higher costs linked to carbon constraints, while competing imports are not subject to equivalent requirements. There is an urgent need to act in order to prevent further delocalisation.
You can find the full text of the Joint Statement in the Download section below.
CEO Position: CBAM Must Protect Europe’s Industrial Value Chains – Not Leave Them Exposed
3 March 2026
European Tool Association calling on the European Parliament and the Council to correct the current imbalance of CBAM and amend the Commission proposals accordingly. CBAM can only be credible if it protects Europe’s industrial value chains in their entirety, not just their first link.
To remedy this, CEO explicitly calls for the inclusion of the relevant CN tariff codes for hand tools, measuring tools and power tool accessories (in particular CN Chapter 82 and relevant products under Chapter 90) in CBAM.
You can find the full text of the CEO Position Paper in the Download section below.
CEO Position on Steel as a key raw material for the European tool industry
2 March 2026
European tool industry calling for inclusion of downstream products such as hand tools, power tool accessories and measuring tools, in EU Carbon Border Adjustment Mechanism (CBAM) and the inclusion of downstream products immediately AND enable re-exports to be competitive in the framework of the EU Steel Safeguard Measures.
Steel is a key raw material for the tool industry: it is indispensable for the quality, durability, and safety of many tools. That is why two regulatory approaches currently under discussion must be designed in such a way that they protect Europe's industrial value creation as a whole: the CO₂ border adjustment mechanism (CBAM) and the EU Steel Safeguard Measures. Both are interventions in trade, but under the current conditions in the EU, they are still necessary as long as they are proportionate, prevent abuse, and do not place a unilateral burden on European manufacturers.
You can find the full text of the CEO Position Paper in the Download section below.
Joint Industry Position of Downstream Metal Industries on CBAM
15 November 2025
CBAM remains a crucial issue for Europe’s downstream metal industries. As the segment responsible for the largest share of industrial value creation, downstream metal processors are significantly affected by CBAM yet are not adequately represented in the current framework.
Against this backdrop, six European associations have published a joint position paper highlighting the specific challenges for downstream industries and calling for a balanced, competitiveness-oriented design of CBAM.
Updated CEO Position on EU Carbon Border Adjustment Mechanism (CBAM)
3 April 2025
The European tool industry is an integral part of the EU’s manufacturing ecosystem, supplying essential sectors such as construction, automotive, aerospace, and defense. However, the industry faces increasing competitive pressure due to its exclusion from the Carbon Border Adjustment Mechanism (CBAM). While CBAM was introduced to prevent carbon leakage and ensure a level playing field for European producers, hand tools, power tool accessories and measuring tools remain outside its scope despite their significant reliance on raw materials, in particular steel, which are being regulated by CBAM.
We, the European Tool Association CEO, call on the European Commission and Members of the European Parliament to amend the CBAM annex to include hand tools, power tool accessories and measuring tools, thereby ensuring that imported products are subject to the same carbon pricing mechanisms as their European-produced counterparts. In addition, we urge policymakers to go beyond mere administrative simplification and engage in meaningful structural improvements to CBAM, that would lead to a reduction of bureaucratic burdens and re-establish a level playing field with non-EU manufacturers.
You can find the full text of the CEO Position Paper in the Download section below.
CEO Position on EU Carbon Border Adjustment Mechanism (CBAM)
16 September 2024
We welcome the introduction of the EU Carbon Border Adjustment Mechanism (CBAM) aimed at offsetting competitive disadvantages for European companies and preventing the relocation of production facilities outside the EU (carbon leakage).
However, in its current form CBAM only applies to raw materials such as steel and some narrowly defined downstream products (e.g. construction fixings such as screws and metal anchors). It does not apply to finished complex goods such as hand tools and power tool accessories despite their high steel content. Hence non-EU producers would be allowed to export their finished goods to the EU internal market without the need to acquire CBAM certificates for their products.
Against this background, we call on the European Commission to propose the inclusion of hand tools and power tool accessories under HS Codes 82 in the Annex of Regulation (EU) 2023/956. This will re-establish a level-playing with non-EU producers of hand tools and power tool accessories in the EU Single Market and safeguard the competitiveness of European producers of these products.
You can find the full text of the CEO Position Paper in the Download section below.
[1] Data source: Latest available EUROSTAT figures (2020)