Letter on CBAM to the European Commission

25 November 2025

To: European Commission
President Ursula von der Leyen
Vice President Teresa Ribera, Stéphane Séjourné
Commissioner Maroš Šefčovič, Valdis Dombrovskis, Wopke Hoekstra, Jessika Roswall

Rue de la Loi / Wetstraat 200
1049 Brussels
Belgium

Dear President,
Dear Vice Presidents,
Dear Commissioners,

We are writing to you as CEOs and executives of companies with significant appliance manufacturing operations and steel production in the EU. Our companies fully support the climate targets of the EU and the mechanism to gradually expand the carbon pricing scope through removal of the free allowances of the EU ETS, starting from 2026. We also support the Carbon Border Adjustment Mechanism (CBAM) aim to ensure the carbon price of imports is equivalent to the carbon price of domestic production, preventing carbon leakage and ensuring that the EU's climate goals and competitiveness of EU companies are not undermined.

While we fully support the aim of CBAM, we are concerned as CBAM in its current form only applies to imported raw material, particularly steel and aluminum and to some components made of steel and aluminum.

In its current form CBAM does not cover complete products, so called finished-goods, that contain a

significant amount of steel and aluminum when imported to the EU. Such products must be included in CBAM to maintain a competitive environment in Europe while avoiding carbon leakage.

If they are not included, this could encourage the relocation of steel-consuming industries to third countries, which would be detrimental for the EU appliance and steel producers, consumers, EU competitiveness, and the climate.

For example, EU manufacturing of finished goods that contain a large content of steel and aluminum, such as household appliances and equipment for heating, cooling and ventilation of buildings and for domestic hot water, will be exposed to a new, unjustified competitive disadvantage from imported finished goods of the same type. This undermines Europe’s manufacturing industry and weakens our competitiveness – a challenge which we are already struggling with.

Business decisions are taken many years ahead of investments in production lines of future models. With the gaps in the current ETS and CBAM proposals, businesses are getting the signal that they can produce finished goods outside the EU and then import these to the EU without additional costs or fees.

In addition, imported goods are in many cases not produced in countries that have similar legislation to control greenhouse gas emissions, which means there is an added negative effect on the climate.

These unwanted effects of the EU ETS and CBAM policy can still be corrected.

We ask that CBAM is extended to include imported finished goods, such as appliances, that contain a significant amount of steel and aluminum. There are several different methods to calculate embedded carbon emissions in imported finished goods, including the use of default values set on a realistic level of the origin country’s emissions.

In addition, we ask that a new export compensation mechanism is created to balance out new indirect cost from the ETS on steel- and aluminum-intensive EU production. Products produced in the EU also need to remain competitive on international markets.

While CBAM must be implemented starting 2026, there is still time to expand it to ensure level playing field also for the steel-intensive appliance sectors. Our proposals would prevent further deterioration of EU competitiveness and manufacturing, keeping manufacturing jobs in the EU, and maintaining a robust mechanism to continue combating climate change.

Yours sincerely,

This letter and contact information is available on:
https://www.electroluxgroup.co...