CBAM Phase 2: Hydrogen and Electricity Scope Expansion — What African Exporters Need to Know
The European Commission has confirmed that CBAM Phase 2 will expand to cover additional sectors including organic chemicals, polymers, and further downstream steel and aluminium products. African exporters in these sectors should begin preparing now.
CBAM Phase 2 Expansion: What's Coming
The European Commission has confirmed that CBAM will expand beyond its current six sectors (steel, aluminium, cement, fertilisers, hydrogen, electricity) in Phase 2. The expansion is expected to cover:
- Organic chemicals — including methanol, ethylene, and other carbon-intensive chemicals
- Polymers — including polyethylene and polypropylene
- Downstream steel products — including pipes, tubes, and structural sections not currently covered
- Additional aluminium products — including foil and extended profiles
The Phase 2 timeline has not been formally confirmed but is expected to begin no earlier than 2028.
Impact on African Exporters
For African exporters, the Phase 2 expansion is most significant for:
- South Africa — downstream steel products from ArcelorMittal SA and other producers
- Egypt — organic chemicals and polymers from the Suez Canal Economic Zone
- Morocco — phosphate-based chemicals beyond the current fertiliser scope
What to Do Now
Exporters in potentially affected sectors should: (1) identify their CN codes against the proposed Phase 2 scope; (2) begin embedded emission measurement for products not currently covered; (3) register at the Digital Product Passport Registry to establish their compliance infrastructure before Phase 2 takes effect.
Read the full CBAM Phase 2 Expansion article for detailed sector coverage.
CBAM compliance requires a registered Authorised Declarant and verified emission data. Begin your registration at the Digital Product Passport Registry.
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