{"id":6268,"date":"2026-09-23T14:09:41","date_gmt":"2026-09-23T11:09:41","guid":{"rendered":"https:\/\/aesinn.com\/enerji-danismanligi\/cbam-kapsam-genislemesi-alt-akis-downstream-urunler-ve-2028-takvimi\/"},"modified":"2026-09-28T14:18:02","modified_gmt":"2026-09-28T11:18:02","slug":"cbam-kapsam-genislemesi-alt-akis-downstream-urunler-ve-2028-takvimi","status":"publish","type":"page","link":"https:\/\/aesinn.com\/en\/enerji-danismanligi\/cbam-kapsam-genislemesi-alt-akis-downstream-urunler-ve-2028-takvimi\/","title":{"rendered":"CBAM Scope Expansion: Downstream Products and the 2028 Timeline"},"content":{"rendered":"<h2 class=\"wp-block-heading\">The focus of this briefing is on scope expansion, not general CBAM.<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The general operation of CBAM, its transition and definitive periods, exemption threshold, and embedded emissions logic are discussed in depth in our related content. This page focuses solely on a new development: the expansion of CBAM coverage beyond the current six sectors to include downstream, or treated products, and its timeline for 2028.<\/p>\n\n\n\n<div class=\"aes-ortak-notu\" style=\"border-left:4px solid #CE1A1A;background:#f6f6f6;padding:14px 18px;margin:18px 0 22px 0;font-size:15px;line-height:1.6;color:#222;\"><strong>Service note:<\/strong> AES Innovation carries out the EU compliance work described on this page (PPWR, digital product passport, CBAM, etc.) in collaboration with expert solution partners; it does not provide these services directly. These activities are outside the scope of our accreditation (EU-0631-M).<\/div>\n\n\n\n<p class=\"wp-block-paragraph\">The Border Carbon Adjustment Mechanism (CBAM) entered its definitive phase on 1 January 2026 with Regulation (EU) 2023\/956. The six sectors covered in this phase are iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity. The issue here is the transition from the raw inputs of these sectors to the processed products manufactured from them.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Greenhouse gas verification standards (ISO 14064 and ISO 14067) are explained in a separate article.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Current scope (2026): iron and steel, aluminum, cement, fertilizers, hydrogen, electricity.<\/li>\n\n\n<li>The subject of this page: expansion into processed (downstream) products manufactured from these raw materials.<\/li>\n\n\n<li>For the general mechanism, transition period, and exemption threshold, please see our relevant content.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">What is a Downstream Product?<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">A downstream product refers to a finished product obtained by processing a raw metal within the scope. For example, raw steel or aluminum undergoes processes such as cutting, casting, welding, and assembly to become a machine body, a vehicle part, or a household appliance component. Until now, these processed products were outside the direct scope of CBAM.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">One of the main reasons for expanding the scope is to prevent anti-circumvention. There was a risk of raw steel or aluminum being slightly processed before importation, thereby excluding the product from the scope and avoiding costs. Including downstream products aims to narrow this gap.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Raw metal \u2192 processing \u2192 machinery, vehicle parts, household appliances, processed metal, construction equipment<\/li>\n\n\n<li>Rationale for expansion: to prevent the risk of lightly processing raw metal and thus escaping the scope.<\/li>\n\n\n<li>Objective: To be able to track embodied emissions in products manufactured by the six existing sectors.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Current Status: Council Agreement and the 2028 Target<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The European Commission presented a proposal on December 17, 2025. Following this proposal, the EU Council agreed on June 12, 2026, to include downstream steel and aluminum products from January 1, 2028. The list under consideration includes approximately 180 processed products (such as machinery, vehicle parts, household appliances, processed metal products, and construction equipment).<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">An important caveat is necessary at this point: the scope of approximately 180 products and the date of January 1, 2028, are at the level of Council agreement. The legislative process is not yet complete; the final legislative text and the complete list of products will be finalized upon publication in the Official Gazette (EU Official Gazette). Therefore, at this stage, the situation is not finalized or in effect; the process is targeted for 2028, and the final text is awaited.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Organic chemicals, polymers, and plastics are considered medium-term candidates. However, due to technical difficulties in calculating embodied emissions in these product groups, they are not yet tied to an expansion proposal; they are not included in the scope, only candidates.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>December 17, 2025: Commission proposal<\/li>\n\n\n<li>June 12, 2026: The Council agrees to include downstream steel and aluminum from 2028.<\/li>\n\n\n<li>Approximately 180 processed products are being considered (final list pending).<\/li>\n\n\n<li>Organic chemicals, polymers and plastics: candidate, not yet decided.<\/li>\n\n\n<li>Note: At the level of Council consensus; the final text and complete list will be finalized with the Official Gazette.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Impact on Turkish Exporters: A Much Broader Industrial Sector<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">This is the most critical point for Turkish industry on this page. Until now, CBAM has mainly affected exporters of crude steel and aluminum. With downstream expansion, manufacturers of machinery, white goods, vehicle parts, and processed metal products could also be included, with a target of 2028. This means that a much broader manufacturing sector, which constitutes T\u00fcrkiye&#039;s export power, will be directly affected.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Therefore, it is recommended that producers likely to be affected begin preparations now rather than waiting. Monitoring embedded steel and aluminum emissions in products and collecting reliable data from the supply chain is a fundamental competency that needs to be established before 2028. Generating real data for embedded emissions is becoming increasingly crucial because when real data is not available, default values come into play, and an increasing mark-up is applied to these values over time (a lower mark-up at the start of the mechanism and a higher one in subsequent years). Specific rates and amounts are not given on this page as they are subject to the EU Emissions Trading System.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">On the Turkish side, the possibility of offsetting carbon payments made on-site through the national emissions trading system established under the Climate Law No. 7552 is also on the agenda; the details of this issue are discussed in our relevant CBAM content.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>To date, mainly exporters of crude steel and aluminum have been affected.<\/li>\n\n\n<li>With a target for 2028, exporters of machinery, white goods, vehicle parts, and processed metal products could also be included.<\/li>\n\n\n<li>What needs to be done now: monitoring embodied emissions and collecting data from the supplier.<\/li>\n\n\n<li>Generating real data is critical; otherwise, default values with incremental markup will be activated.<\/li>\n\n\n<li>For information on the possibility of offsetting national ETS (Electricity Transactions) under Climate Law No. 7552, please see our relevant content.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Methodological Changes in the Field of Electricity<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">In electricity, one of the six sectors covered, the methodological approach to calculating embodied emissions is being updated from 2026 onwards. This is a technical regulation on how emission intensity of electricity flows will be attributed and is a separate topic from sub-stream expansion; it is mentioned here for informational purposes only.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>The methodology for calculating electricity emissions is being updated from 2026.<\/li>\n\n\n<li>This is a technical arrangement, separate from downstream expansion.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">What Needs to Be Done by 2028? Preparation Roadmap<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Even while awaiting the final legislative text, preparation for potentially affected manufacturers is a task that should not be delayed. The following steps can be considered a starting point for making embedded emissions data manageable from today.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Identify the items in your product portfolio that contain steel and aluminum, and their export markets.<\/li>\n\n\n<li>For each product, map the amount of metal it contains and its source (supplier).<\/li>\n\n\n<li>Set up the process now to request embedded emissions data from suppliers.<\/li>\n\n\n<li>Plan a measurement infrastructure based on real production data to reduce reliance on default values.<\/li>\n\n\n<li>Follow the legislative process and the publication of the final product list in the Official Gazette.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Information Note<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">This content is for informational purposes only. AES is not an approved body or certification body and does not perform CBAM embedded emission verification. CBAM verification is the responsibility of greenhouse gas verification bodies accredited under ISO 14065. AES&#039;s T\u00dcRKAK accreditation is only for the scope of 6.1 Electrical Installation inspection.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">For your electrical installation safety and regulatory compliance inspection needs, we are pleased to provide information and support with our team of qualified engineers. Please note that for CBAM embedded emission verification, you should apply to the relevant accredited verification bodies.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Related Services and Content<\/h2>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li><a href=\"https:\/\/aesinn.com\/en\/cbam-ab-sinirda-karbon-duzenleme-mekanizmasi-ve-turk-ihracatcisina-etkisi\/\">CBAM: The EU Border Carbon Adjustment Mechanism and its Impact on Turkish Exporters<\/a><\/li>\n\n\n<li><a href=\"https:\/\/aesinn.com\/en\/enerji-danismanligi\/iso-14064-ve-iso-14067-bilgilendirmesi-sera-gazi-dogrulama-ve-urun-karbon-ayak-izi-cbam-baglaminda\/\">ISO 14064 and ISO 14067: Greenhouse Gas Verification and Product Carbon Footprint<\/a><\/li>\n\n\n<li><a href=\"https:\/\/aesinn.com\/en\/uyum-denetim-due-diligence-danismanligi\/dijital-urun-pasaportu-dpp\/celik-sektorunde-dijital-urun-pasaportu-dpp-espr-kapsaminda-karbon-geri-donusum-ve-izlenebilirlik-verisi\/\">Digital Product Passport (DPP) in the Steel Industry<\/a><\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Frequently Asked Questions<\/h2>\n\n\n\n<h3 class=\"wp-block-heading\">What exactly does CBAM scope expansion mean?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">This refers to expanding beyond the existing six sectors (iron and steel, aluminum, cement, fertilizers, hydrogen, electricity) to include processed, or downstream, products made from these metals. The EU Council has agreed to include downstream steel and aluminum products from January 1, 2028; however, the final legislative text is awaited.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Are the 180 products and the January 1, 2028 date finalized?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">No, it&#039;s not finalized. The approximately 180 processed products and the date of January 1, 2028 are at the level of the Council agreement of June 12, 2026. The full product list and date are not final until the legislative process is complete; finalization will occur with publication in the Official Journal of the EU. At this stage, 2028 is targeted and the final text is awaited.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Which Turkish exporters might be affected by this expansion?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Until now, mainly exporters of crude steel and aluminum have been affected. With downstream expansion, exporters of machinery, white goods, vehicle parts, and processed metal products could also be included by 2028. This means a much broader Turkish manufacturing sector will be affected.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Do organic chemicals and plastics also fall under the scope?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">No. Organic chemicals, polymers, and plastics are considered medium-term candidates; however, due to technical challenges in the embodied emissions account, no expansion decision has yet been made. They are not currently included in the coverage, only candidates.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">What should manufacturers do now, without waiting until 2028?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">It should start monitoring embedded steel and aluminum emissions in its products and collecting reliable data from its suppliers now. Establishing a measurement infrastructure based on real production data is increasingly important, as incremental mark-up default values come into play when real data is not produced.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Can AES perform CBAM verification for us?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">No. AES is not an approved body or certification body and does not perform CBAM embedded emissions verification. This verification is the job of greenhouse gas verification bodies accredited under ISO 14065. AES&#039;s T\u00dcRKAK accreditation is only for section 6.1 Electrical Installation inspection. This content is for informational purposes only.<\/p>","protected":false},"excerpt":{"rendered":"<p>CBAM yaln\u0131zca ham metal ihracat\u00e7\u0131s\u0131n\u0131 de\u011fil; 2028&#8217;den itibaren makine, beyaz e\u015fya ve ara\u00e7 par\u00e7as\u0131 gibi i\u015flenmi\u015f \u00fcr\u00fcn ihracat\u00e7\u0131lar\u0131n\u0131 da kapsayabilir. Bu bilgilendirme, alt-ak\u0131\u015f (downstream) geni\u015flemesini ve g\u00fcncel takvimi ele al\u0131r.<\/p>","protected":false},"author":1,"featured_media":6269,"parent":3254,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"_kad_blocks_custom_css":"","_kad_blocks_head_custom_js":"","_kad_blocks_body_custom_js":"","_kad_blocks_footer_custom_js":"","_kadence_starter_templates_imported_post":false,"_kad_post_transparent":"","_kad_post_title":"","_kad_post_layout":"","_kad_post_sidebar_id":"","_kad_post_content_style":"","_kad_post_vertical_padding":"","_kad_post_feature":"","_kad_post_feature_position":"","_kad_post_header":false,"_kad_post_footer":false,"_kad_post_classname":"","slim_seo":{"title":"CBAM Downstream Products and 2028 Calendar","description":"CBAM's expansion into downstream steel and aluminum products, the 2028 timeline, and its impact on Turkish machinery, white goods, and vehicle parts exporters."},"_pplb_hide_from_list":false,"footnotes":""},"class_list":["post-6268","page","type-page","status-publish","has-post-thumbnail","hentry"],"acf":[],"taxonomy_info":[],"featured_image_src_large":["https:\/\/aesinn.com\/wp-content\/uploads\/cbam-downstream-aes-kart-1024x1024.png",1024,1024,true],"author_info":{"display_name":"Emre Metin","author_link":"https:\/\/aesinn.com\/en\/author\/yonetim\/"},"comment_info":"","_hostinger_reach_plugin_has_subscription_block":false,"_hostinger_reach_plugin_is_elementor":false,"_links":{"self":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6268","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/comments?post=6268"}],"version-history":[{"count":3,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6268\/revisions"}],"predecessor-version":[{"id":6299,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6268\/revisions\/6299"}],"up":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/3254"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/media\/6269"}],"wp:attachment":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/media?parent=6268"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}