The EU Carbon Border Adjustment Mechanism (CBAM) will officially take effect on January 1, 2026, initially covering six high-energy-consuming sectors: steel, aluminum, cement, fertilizers, electricity, and hydrogen. Recently, the European Commission released the CBAM Annual Assessment Report, systematically reviewing the mechanism's performance during the transition period and progress in international cooperation, clarifying pathways to enhance its effectiveness, and notably disclosing plans for the second phase of expansion—approximately 120 chemicals have been included in the potential scope of regulation. This move has not only become a focal point for petrochemical companies exporting to the EU but also marks the formal extension of CBAM expansion into the highly complex chemical sector.

The report specifies that the EU employs a multi-stage screening method for industries potentially included in CBAM expansion: first, defining the preliminary scope based on carbon leakage risks, industry representativeness, and emission scale; then conducting in-depth analysis incorporating production structure, economic significance, and trade data. Given the diverse and complex nature of the chemical industry with its lengthy supply chains, the EU innovatively proposes a "key substances-centered" value chain assessment approach. This method focuses on single chemicals and their related substances with high production volumes, high emissions, or established carbon market benchmarks, ensuring precise coverage of core emission links and avoiding regulatory gaps due to industry complexity.

In the first list of potential expansion products, over 120 chemicals and polymers have been identified as key assessment targets, covering multiple sub-categories such as olefins, aromatics, methanol, plastic polymers, naphtha, pyrolysis gasoline, and reformate. The selection of these products strictly adheres to three criteria: "high production volume, high emissions, and established EU Emissions Trading System (ETS) product benchmarks." This not only ensures the precision and feasibility of regulatory policies but also aligns closely with the expansion logic proposed in the report: "first cover core high-emission substances, then gradually extend to the entire industrial chain."

From a timeline perspective, 2027 will be the critical decision-making window for CBAM expansion. According to the plan, CBAM will conclude its transition period and commence full operation in 2026, simultaneously initiating the accumulation of import emission data for the first complete year. By 2027, the European Commission must submit a new assessment report based on the actual operational data from 2026 and propose legally binding legislative recommendations on whether to formally include new sectors, such as chemicals, under CBAM regulation.

Market analysts point out that if over 120 chemical products are ultimately included in the CBAM regulatory list, it will trigger profound strategic restructuring in the global chemical and petrochemical industries. At its core, CBAM is not merely an environmental tax but a geopolitical economic tool through which the EU systematically transfers its high internal carbon costs to global supply chains, reshaping international trade rules via green barriers. For the chemical industry, characterized by high energy intensity, diverse process routes, and highly globalized supply chains, this move will directly impact core industrial competitiveness, compelling relevant enterprises to accelerate low-carbon transitions and adjust their supply chain layouts.