Module 2 of 9 · A1 · Which aluminium goods are covered
7.What may change: proposals to watch (not law)
A Commission proposal of 17 December 2025 would:
- extend CBAM to some downstream goods containing aluminium or steel (for example certain fittings);
- make pre-consumer aluminium scrap a precursor, so its emissions count. Today it counts as zero.
This is not law yet. If you use a lot of pre-consumer scrap, start recording its share and sources now; you already report the share as a parameter (see A5).
Sources: COM989 p.1, recitals 19-20, explanatory memorandum, Annex.