The European Solar Manufacturing Council (ESMC) has urged the European Commission to expand the scope of the Carbon Border Adjustment Mechanism (CBAM) to include key downstream solar products such as solar modules, mounting systems, and trackers. In its response to the Commission’s ongoing consultation on CBAM’s future coverage, ESMC highlighted how the current exclusion of these products undermines the mechanism’s effectiveness and gives non-EU manufacturers an unfair competitive edge.
“These products rely heavily on carbon-intensive materials such as aluminium and steel, which are already covered by CBAM,” ESMC noted in its feedback. “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.”
Jens Holm, Policy Director at ESMC, emphasized the potential impact of expanding CBAM. “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,” he said.
ESMC’s proposal aims to ensure that imported solar products face the same carbon costs as domestically manufactured equipment. The move, they argue, would strengthen the integrity of CBAM, create a level playing field, and help secure Europe’s solar industrial base at a time of intense global competition.
CBAM is set to come into force on 1 January 2026. Importers will be required to purchase certificates that reflect the embedded emissions of covered products, aligned with the EU Emissions Trading System (ETS), which currently prices carbon at €72 per ton. As of now, sectors such as cement, electricity, fertilizers, iron and steel, aluminium, and hydrogen are included in the mechanism.
The European Commission is expected to review ESMC’s proposal along with other stakeholder inputs later this autumn. The decision could have far-reaching implications for the future of Europe’s solar manufacturing sector and its broader climate goals.
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