Summary
- The Office of the United States Trade Representative is seeking comments on the current and potential effects of the EU Carbon Border Adjustment Mechanism on US producers, workers, exports and overall EU-US trade.
- The consultation covers compliance costs, regulatory burdens, EU market access, competitive effects and the proposed expansion of CBAM to downstream steel- and aluminium-intensive products.
- Comments under docket USTR-2026-0661 are due by 9 November 2026; the notice asks whether enforcement action may be appropriate but does not itself launch an investigation or change CBAM rules.
Extended article
On 8 October 2026, the Office of the United States Trade Representative published a Federal Register notice requesting evidence on how the European Union’s Carbon Border Adjustment Mechanism affects US businesses and trade. The consultation specifically covers small and medium-sized producers, workers, direct and indirect exports and overall bilateral trade.
CBAM’s definitive phase began on 1 January 2026. It currently covers selected products in the aluminium, cement, electricity, fertiliser, hydrogen, iron and steel sectors. EU importers must determine embedded emissions and acquire CBAM certificates priced by reference to EU Emissions Trading System allowance auctions. Covered imports made from 1 January 2026 are accruing obligations, although certificate surrender and payment begin later under the implementation timetable described in the notice.
USTR is also gathering views on proposals from the European Commission, Council and Parliament to extend CBAM to additional downstream products. The notice asks stakeholders to address costs, processes, market access, comparative effects on US, EU and third-country businesses, and possible enforcement action to remedy negative effects.
Submissions may include product-level data, trade values, lost sales, employment effects, producer size and geographic information. The consultation is an evidence-gathering exercise intended to inform further US government engagement with the EU. It does not announce tariffs, retaliation, a Section 301 investigation or any amendment to Regulation (EU) 2023/956.
Source
- US Federal Register: Request for Comments on EU CBAM and Proposed Scope Expansion
- US Small Business Administration Office of Advocacy: USTR Seeks Comments on EU CBAM
- European Commission: Carbon Border Adjustment Mechanism
- EUR-Lex: Regulation (EU) 2023/956 Establishing CBAM
- Akin: USTR Seeks Business Input on the EU Carbon Border Adjustment Mechanism
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