Insights / CBAM
Do Imported Transformers, Motors and Cables Fall Under CBAM?
Do finished transformers (8504), motors (8501) or insulated cables (8544) count as CBAM goods?
No, not today. Chapter 85 goods are not in Annex I of Regulation (EU) 2023/956, so they carry no CBAM duty and do not count toward the 50 tonne threshold. A Commission proposal of 17 December 2025, COM(2025) 989, would extend CBAM to some downstream steel and aluminium intensive goods from 2028; it is a proposal, not law.
What the act says
- Annex I: Lists cement, electricity, fertilisers, hydrogen, iron and steel and aluminium by CN code; Chapter 85 is not among them.
- COM(2025) 989: A proposal: which headings it would add, and from when, is decided only when it is adopted.
What to do
- Keep finished electrical equipment out of your CBAM tonnage.
- Watch COM(2025) 989 if you import steel-intensive finished goods.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- COM(2025) 989, proposal to extend CBAM to downstream goods
Last checked against the act text on 2026-10-20. For information only, not legal advice.