ECOS | Environmental Coalition on Standards

18 July 2026

Making the Carbon Border Adjustment Mechanism work for reuse

Reuse is not relevant for the majority goods covered by the Carbon Border Adjustment Mechanism. This is because many intermediate goods - such as cement, fertiliser, electricity or hydrogen - cannot be reused. However, iron, steel, and aluminium are different, which might end up being reused in construction or infrastructure works.

The trade of reused goods is still in its early days, but ECOS believes that it is important to fix reuse blockages in the CBAM. Doing so would support the EU’s ambitions to transition to and be a global leader in circular economy. This position paper puts forward two potential solutions: expanding the Combined Nomenclature (CN) codes or introducing rules on reuse in the CBAM acquis. 

 

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ECOS is co-funded by the European Commission and EFTA Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or EISMEA. Neither the European Union nor the granting authority can be held responsible for them.

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