The following comments were submitted on the 18th of November 2025 to the Finnish Parliament's Economic Affairs Committee regarding Finnish position on the European Commission's implementing regulation on the calculation methodology for product-specific emissions under the Carbon Border Adjustment Mechanism (CBAM).

Our statement emphasized that CBAM is not merely an economic instrument, but a strategic climate policy tool. Its aim is to protect EU industry from unfair competition and steer global production towards low emissions.

We support the Commission’s proposal as it prevents ’resource shuffling’ and makes it possible to use conservative default values if actual values are not available.

However, as CBAM expands to downstream products, the impacts of the Commission’s proposal will vary depending on the role of the operators. For some, the mechanism will appropriately provide competitive protection, but for importers of intermediate products, it may lead to increased costs, more bureaucracy, and reduced competitiveness.

Therefore, we call for the need for impact assessments. The Commission should organize a public consultation – this has not been done yet. Looking ahead, we consider it highly desirable that the Commission's proposal for a possible extension of the CBAM in value chains be accompanied by a thorough impact assessment, examining both the competitiveness impacts of the extension on the various actors in the value chains and its climate impacts.

Read and download the full statement below (in Finnish).