For now, yes. But the list expands with each round: when legislation was enacted in 2023 it only covered materials and a few finished products; the proposal in December 2025 (COM(2025) 989) proposes to add approximately 180 downstream steel and aluminum products, effective January 1, 2028. The European Parliament's Environment Committee even advocates expanding to 277 products. If your product is primarily made of steel or aluminum, we recommend you start keeping energy consumption and material records now.
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