Feedback to Consultation on the CBAM Downstream Extension

A blunt downstream extension of CBAM would prove difficult for many of our members due to complex supply chains. PV modules and batteries are made of many components (frames, screws, cables, junction boxes, cells, etc.) sourced from different suppliers worldwide. Tracing the embedded emissions of each input is technically unworkable with today’s systems. 

In addition, companies struggle to obtain reliable emissions data from suppliers, who may be unwilling or unable to provide it. Global discrepancies in carbon pricing make it nearly impossible to translate foreign costs into CBAM-compliant figures. Compliance with such an extension would require entirely new systems for emissions tracking, internal reporting, and supplier coordination, plus extra staffing or consultancy support, a disproportionate cost, especially for SMEs.

While it is very important that the EU uses regulation to disclose and improve the carbon emissions of products marketed in the EU, this objective is best advanced by further developing existing product-specific regulatory frameworks such as the Ecodesign and Energy Label regulations. Existing frameworks (Ecodesign for PV, Batteries Regulation) already provide product-specific carbon footprint methodologies that are more suitable for tackling emissions than a blunt CBAM extension. For instance, Ecodesign for solar PV will set mandatory minimum requirements to eliminate least sustainable products from the market, while taking a lifecycle approach that considers emissions on the product level rather than on specific embedded components. 

As outlined above, a blunt downstream CBAM extension should not apply to all solar and battery storage segments. However, with respect to mounting structures, identifying embedded emissions is more feasible. These products are generally manufactured using standardised steel or aluminium inputs with clear sourcing and emissions data. For these components, that are essentially covered by the '7610’ (aluminium structures) and '7308’ (steel structures) customs codes already included in the current CBAM scope, maintaining CBAM will play a valuable role in supporting environmental transparency and protecting EU producers from low-cost, and high-emission imports. 

However, should CBAM be extended to mounting structures, it will be essential to first conduct a thorough impact assessment to understand potential consequences for availability, pricing, and supply resilience. Any implementation should follow a gradual, phased approach that allows market actors to adapt without causing product shortages or sudden price spikes.

SolarPower Europe highlights the risk of CBAM circumvention, particularly in mounting structures, where minimal processing of steel or aluminium abroad can avoid coverage and undercut EU producers by up to 20%. Including mounting systems within CBAM would help prevent such distortions and protect EU manufacturers investing in low-carbon production — but this should not justify a blanket extension to complex products like PV modules or batteries.