In the ESMC feedback to the European Commission’s consultation on the future scope of the Carbon Border Adjustment Mechanism (CBAM), ESMC urges the Commission to extend CBAM to key downstream solar products such as modules, mounting systems, and solar trackers.
These products rely heavily on carbon-intensive materials such as aluminium and steel, which are already covered by CBAM. However, finished solar equipment imported into the EU currently avoids the carbon costs faced by European manufacturers. This loophole gives non-EU manufacturers, particularly in China, an unfair advantage and undermines CBAM’s core objective of preventing carbon leakage.
“Extending CBAM to downstream solar PV goods would make Chinese solar modules, trackers, and systems more expensive and give European manufacturers a long-awaited competitive advantage. By doing so, CBAM could become one of the most effective anti-circumvention measures and substantially contribute to Europe’s green-tech industrial revival,” says Jens Holm, Policy Director at ESMC, in the submission.
By extending CBAM to cover solar modules, trackers, and mounting systems, the EU would ensure that imported products bear the same carbon cost as EU-made equipment. This would strengthen the integrity of the mechanism, create a genuine level playing field, and help secure Europe’s solar industrial base at a time of severe competitive pressure.
From 1 January 2026, the Carbon Border Adjustment Mechanism enters into force and importers will need to purchase CBAM certificates that reflect the embedded emissions of covered products. The purpose is to prevent carbon leakage by imposing the same carbon price as in the EU ETS (currently €72/ton). At present, the following goods are covered by CBAM: cement, electricity, fertilizers, iron and steel, aluminium, and hydrogen. The European Union is expected to respond to ESMC’s proposal and others later this autumn.
Solar products to be included in EU Carbon Border Adjustment Mechanism
