As a strongly export-oriented sector relying on global value chains, our industry is already feeling the practical implications of CBAM. While we fully support the EU’s climate objectives, the current framework raises serious concerns for downstream manufacturing sectors:
- Rising production costs linked to steel and aluminium inputs
- Distorted competition, both on EU markets and globally
- Legal uncertainty, especially for long-term, fixed-price projects
- Significant administrative burden, particularly for SMEs
Without targeted adjustments, CBAM risks weakening the competitiveness of European manufacturers and accelerating deindustrialisation—precisely when strengthening Europe’s industrial base is a strategic priority.
FEM calls for:
- A postponement of CBAM obligations for downstream users
- A comprehensive impact assessment before full implementation
- Greater legal certainty for industrial projects
- Measures to address competitiveness risks and reduce administrative burden
A well-designed CBAM must strike the right balance: delivering on climate ambition while preserving a strong, innovative, and competitive European industry.

