EU carbon rules / Product life cycle / L1 Raw materials & sourcing
L1 4 regulations 3 compilations
Raw materials & sourcing
Deforestation traceability (EUDR), critical raw materials and supply-chain due diligence already apply at the sourcing stage.
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Regulations at this stage
| Regulation | Reference | Status | Key date | Applies to |
|---|---|---|---|---|
| LULUCF Amendment | Regulation (EU) 2023/839 | In force | 2023 | Land use, forestry |
| Critical Raw Materials Act CRMA | Regulation (EU) 2024/1252 | In force | 2024 | Companies extracting, processing and importing critical raw materials |
| Deforestation Regulation EUDR | Regulation (EU) 2023/1115 | In force | 2026-12-30 | Beef, cocoa, coffee, palm oil, rubber, soy, wood |
| Methane Regulation | Regulation (EU) 2024/1787 | In force | 2024 | Energy imports and production |
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Industry dossiers at this stage
- Aluminium and non-ferrous metals Indirect emissions (the electricity mix) are the main variable in CBAM cost; proof of green power is the competitive edge. NACE C24.4–C24.5
- Chemicals and fertilisers Fertilisers and hydrogen are already covered by CBAM; organic chemicals and polymers are candidates for the next extension. NACE C20
- Batteries, machinery, appliances and electronics The battery passport and carbon-footprint declaration are hard gates; metal parts in appliances and machinery face pressure as CBAM extends downstream. NACE C26–C28 et al.
- Pulp and paper Not on the CBAM list, but EUDR timber traceability and PPWR recycled-content rules determine market access. NACE C17
- Agriculture and forestry The CRCF provides voluntary certification for carbon farming and carbon removals; land-use and forestry emissions are accounted under LULUCF, and nutrient management is governed by the Nitrates Directive. NACE A01–A03
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