Provisional benchmarks and default values published on the website were unchanged from those outlined in drafts leaked last week.
The updated CBAM annexes were considered technically final but remained subject to formal adoption and publication in the EU Official Journal. They were expected to be published before December 25, sources familiar with the matter said.
But several European steel industry groups and associations have raised serious concerns while the EU’s CBAM moves toward definitive implementation – scheduled for less than two weeks from now.
Notably, EUROMETAL, the European Federation of Steel, Tube and Metal Distribution & Trade, warned that “CBAM is moving faster on paper than it can be delivered in practice.”
“At the end of 2025,” it said in a statement seen by Fastmarkets on December 17, “the European Commission has provisionally published a large number of detailed CBAM rules for the definitive period, running to hundreds of pages. However, critical elements of the system remain unresolved, including verification capacity, final ETS benchmarks and the treatment of precursors such as scrap.”
EUROMETAL warned that unresolved CBAM rules and insufficient verification capacity would force many companies to rely on default values, triggering significant unbudgeted cost increases across the steel value chain.
“Hundreds of installations are unlikely to be verified on time, despite acting in good faith,” the trade body said. “This creates a structural mismatch between legal obligations and operational reality… As a result, companies will be forced to rely on CBAM default values, not due to non-compliance but because verification is unavailable.”
Although verification will be legally required from 2026 onward, industry sources warned that verification at scale was unlikely before 2027, despite legal obligations.
“There is insufficient verifier capacity, especially outside the EU. Many third-country installations will not be ready or accredited in time,” a source in the EU steel market said.
Indeed, for some countries, default emission values were set at extremely high levels, pushing CBAM costs above €200 ($234) per tonne.
Another concern the association expressed related to the Commission’s recent update was the inclusion of scrap as a CBAM precursor. EUROMETAL noted that scrap cannot currently be traced to reliable emissions data, risking systematic miscalculation and further reliance on default values.
“EUROMETAL fully supports the EU’s climate objectives,” the group’s president, Alexander Julius, said, “but stresses that ambition must be matched by realistic timelines, proportionality and legal certainty. The federation is currently finalizing a formal position letter addressed to the European Commission, which will be submitted early next week.”
European steel association Eurofer welcomed the Commission’s work to close CBAM loopholes but said that current proposals “fall short of ensuring comprehensive and structural solutions.”
While EUROFER acknowledged that several weaknesses – such as risks to exports, downstream sectors and circumvention practices – have been recognized, it said that the proposed fixes were piecemeal, time-limited and insufficient to prevent carbon and jobs leakage.
It also criticized the limited scope of export protection (covering less than one-quarter of steel exports), uncertain funding for transitional measures, weak deterrence against resource shuffling, and narrow downstream coverage, which leaves gaps along the value chain.
It called for structural, long-term solutions to make CBAM “rock-solid and watertight from day one,” warning that without them the mechanism could “backfire” by further penalizing European steelmakers and their customers in a challenging global environment.
The VDMA (Association of German Mechanical and Plant Engineering) was more critical, warning that the downstream CBAM expansion “threatens Europe’s mechanical engineering industry.”
“Adding more products to the scope of CBAM increases complexity, bureaucracy and costs for EU businesses, contradicting the EU’s recent simplification efforts,” Holger Kunze, director of the VDMA’s European office, said on December 17. “This is the wrong signal for Europe’s machinery industry at a time of growing global trade tensions.”
