CLEPA supports the objectives of the EU’s Carbon Border Adjustment Mechanism (CBAM) and recognises its role in preventing carbon leakage and strengthening Europe’s industrial competitiveness. It also acknowledges the long-term rationale for extending CBAM to downstream products.
However, automotive suppliers are already under significant economic pressure while investing heavily in supply chain decarbonisation. The current CBAM methodology does not always recognise these efforts, particularly due to the reliance on default emissions values and limited use of primary data, which can create additional costs for downstream manufacturers. Before any expansion of CBAM’s scope, the EU should ensure the mechanism does not impose further economic burdens and effectively delivers a level playing field.
CLEPA also highlights that major operational and administrative challenges remain unresolved during the current implementation phase. Without simplification, extending CBAM risks increasing compliance costs, complexity and uncertainty for automotive suppliers and other manufacturing industries.
Overall, CLEPA believes the policy debate should focus first on making CBAM economically proportionate, operationally practical and scalable for downstream industries before considering any further expansion of its scope.
