Last December, the European Commission announced its intention to extend the scope of the CBAM (Carbon Border Adjustment Mechanism). This regulation aims at making importers pay the carbon price of certain imported raw materials (to compensate that EU products are subject to ETS). The intention is to protect European companies that are greening their production from unfair international competition.
From 1st January 2028, the scope of the CBAM will be extended to include certain steel- and aluminium-intensive downstream products (see Annex 1 of the proposal by the Commission). Downstream products refer to intermediate products (such as tubes, absorbers, etc.) or also, potentially, finished products (such as solar water heaters).
For sectors that import raw materials or downstream products covered by the CBAM, companies will have to obtain authorised declarant status from customs authorities and pay the carbon border tax. The EU Commission is however planning an exception for SMEs: any importer below the threshold of 50 tons of imported CBAM goods in total per year and who does not import electricity or hydrogen would not be subject to these obligations.
The Board of Directors of Solar Heat Europe confirmed the association’s intention to request the inclusion of solar thermal collectors in the extension of the CBAM. The aim is to protect EU-made solar thermal collectors from cheaper non-EU made products.
At the moment, the draft list of products covered by the CBAM extension only covers raw materials or components of solar thermal systems. See draft in Annex 1 of the proposal by the Commission.
Solar Heat Europe is currently finalising its position on this issue. Members can respond via this form.
Feedback from members is expected by 27 February at the latest.