FEC has joined a broad alliance of European downstream manufacturing associations in calling on the European Parliament, the Council and the European Commission to ensure that the Carbon Border Adjustment Mechanism protects the entire industrial value chain.
Within just a few days, associations representing a wide range of metal-processing industries came together to deliver a strong joint message ahead of the forthcoming CBAM trilogue negotiations.
The joint call, issued on 30 September 2026, stresses that an effective CBAM must protect not only Europe’s basic-material industries, but also the downstream manufacturers that transform iron, steel, aluminium and other metals into marketable products.
Equal rules for equal products
European manufacturers increasingly bear the carbon costs embedded in the materials they process. At the same time, competing finished products imported from third countries may not be subject to an equivalent burden.
This creates a structural imbalance: processing materials in Europe becomes more expensive, while importing the finished product may become comparatively more attractive.
If this imbalance is not addressed, Europe risks losing manufacturing, investment, employment and specialised industrial expertise. Rather than preventing carbon leakage, an incomplete CBAM framework could shift production and emissions outside the European Union.
The central demand of the participating associations is therefore clear:
Equal rules for equal products.
A major part of Europe’s industrial base
Europe’s downstream metal-processing industries represent approximately:
- 415,000 companies;
- 3.8 million jobs; and
- €700 billion in annual turnover.
These industries are predominantly characterised by small and medium-sized enterprises, regional manufacturing clusters, specialised expertise and closely interconnected European supply chains.
Their products range from cookware, cutlery and household goods to tools, locks, fittings, forged components, metal packaging and numerous other industrial and everyday products.
Five priorities for the CBAM trilogue
The joint call asks the trilogue negotiators to:
- Preserve the progress already achieved by retaining all relevant downstream product codes included in the positions of the European Commission, the Council and the European Parliament.
- Maintain the broader downstream coverage adopted by the European Parliament to prevent carbon leakage and reduce the risk of circumvention.
- Include the complete priority CN and HS codes identified by the affected industries.
- Ensure consistent treatment of comparable products with similar material inputs, production processes, carbon-cost exposure and competitive conditions.
- Establish an effective export solution that is predictable, WTO-compatible, administratively workable and accessible to SMEs.
Relevance for the cookware, cutlery and housewares industry
For the industries represented by FEC, the priority product categories include metal household and kitchen articles under headings 7323, 7324, 7615 and 7616, as well as knives, cutlery, scissors and related products under headings 8211 to 8214.
The inclusion of these downstream products is essential to ensure that European manufacturers are not placed at a competitive disadvantage when processing materials subject to increasing carbon costs.
The initiative does not seek special treatment for individual sectors. Its objective is to create a genuine level playing field between products manufactured in Europe and comparable finished products imported into the European market.
A strong joint European message
The initiative brings together associations representing the cookware, cutlery and housewares sector, the foundry and forging industries, tool manufacturers, producers of locks and building hardware, cold-rolled steel, steel and metal-processing industries and metal packaging manufacturers.
The joint call is supported by:
- ARGE – The European Federation of Locks and Building Hardware Manufacturers;
- CEO – European Tool Association;
- CIELFFA;
- European Foundry Federation;
- EUROFORGE;
- Fachvereinigung Kaltwalzwerke;
- Fachverband Schloss- und Beschlagindustrie;
- FEC – Federation of the European Cookware, Cutlery and Housewares Industries;
- Industry Association Steel and Metal Technology – WSM;
- IVSH – German Association of the Cutlery, House- and Cookware Industries;
- Industrieverband Massivumformung; and
- Metal Packaging Europe.
FEC welcomes this strong cooperation between European downstream industries. Climate policy, industrial policy and competitiveness must be considered together to preserve manufacturing, employment and industrial expertise in Europe.
The common message is clear: CBAM must protect the entire European value chain and must not make it more attractive to import finished products than to manufacture them in Europe.
Download the full joint call: CBAM Trilogue – Protect Europe’s Entire Industrial Value Chain