CBAM Expansion: Bureaucracy Costs Are Out of Control
CBAM Expansion: Bureaucracy Costs Are Out of Control

24 September 2026 – Thirteen EU Member States are calling for a year without new obligations. Brussels is providing the proof of why this is urgently needed. What the CBAM expansion will mean in terms of additional bureaucracy, and what it will really cost the companies affected, once again appears to be of little interest to policymakers.

CBAM Expansion: Bureaucracy Costs Are Spiralling Out of Control

On Tuesday, 13 Member States, including Germany, called for a year without new regulations. Austria’s Europe Minister Claudia Bauer compared fighting bureaucracy with new legislation to trying to put out a fire with paper.

One week earlier, the European Parliament approved the next stack of paper. The Carbon Border Adjustment Mechanism, CBAM, which has applied since January to imports including steel, aluminium and cement, is to cover machinery parts, pumps, refrigerators, automotive components and much more from 2028.

European Parliament Votes for Disproportionate Expansion

The Commission had originally proposed expanding CBAM to another 180 product groups. The Council, which also includes the governments that signed the anti bureaucracy paper, largely adopted that list in June and provides for an annual review of what should be added. But the European Parliament simply knew no restraint: at least 457 product groups, plus the entire chapter covering articles of iron and steel, and complete product groups such as pumps, refrigeration equipment and trucks. This addition passed by a majority of just ten votes.

There is no impact assessment for this drastic expansion. Even the Commission’s estimate for its own 180 products is remarkable: another 7,000 companies would have the privilege of dealing with the most complex Regulation Brussels has ever devised. The same authority already puts the administrative burden for CBAM declarants at up to €81,900 per year. In 2021, the figure was still €45,300.

The reason for the gap is simple: Brussels calculates bureaucracy in tonnes. Because the new products account for only a fraction of import volumes, the costs have been artificially reduced on paper. But forms weigh nothing. Authorisation, supplier data, emissions evidence and the annual declaration apply to every company, whether it imports 51 tonnes or 5,000.

What Brussels’ Bureaucratic Madness Really Costs

Because nobody else is doing it, we have extrapolated the figures using the Commission’s own data and Brussels’ own assumptions. Applied to the Parliament’s list, as many as 18,000 additional companies could become subject to CBAM. The number of CBAM declarants would therefore double to 36,000.

Each of these companies faces up to €81,900 per year in CBAM bureaucracy costs. For more complex products, these costs could be as much as 43 per cent higher. Together, that amounts to as much as €2.1 billion annually, plus up to €2.3 billion for IT, consulting and training. And the chapter covering articles of iron and steel, which Parliament wants included in the expansion, is not even part of that calculation.

Exaggerated? The Commission Is a Master of Getting Its Estimates Wrong

Exaggerated? The Commission has already miscalculated once. In 2021, it assumed that around 20,000 CBAM importers would be affected. With the CBAM Omnibus, even the Commission had to admit that more than 200,000 companies were affected by this bureaucratic monster.

Do CBAM Supporters Know What They Are Asking For?

Europe’s steel and aluminium producers have long been pushing for an expansion in order to protect themselves against cheap imports. But the bill is paid primarily by their own customers: machinery manufacturers, suppliers and distributors, most of them small and medium sized enterprises.

Anyone imposing new obligations on these companies weakens precisely the industry that processes European steel. Parliament and Council will now negotiate. The 13 governments can show whether their paper is worth more than the ink it was written with. Bureaucracy is not measured in tonnes. It is measured in companies.

Editorial Note

Against this background, we find it remarkable that certain events provide a platform to those responsible for implementing this system, such as Maria Elena Scoppio, Director for Indirect Taxation and Tax Administration at DG TAXUD. Equally, it is sheer malice to use such a platform to stage a promotional event for a tax.

We deliberately do not wish to name the organiser here, because doing so would only extend that platform further.

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