# EU CBAM 2028 to Cover Construction Equipment: Pre-2028 Buying Window?
The CBAM extension headlines suggest Chinese telehandlers become uncompetitive in the EU after 2028. The actual carbon cost on a 6-tonne machine works out to roughly EUR 400-700 per unit at the proposed 2028 markup. The price gap to EU brands is twenty times that number.
Brussels has confirmed it will fold construction equipment into the Carbon Border Adjustment Mechanism from 1 January 2028. The Commission proposal published on 17 December 2025 lists roughly 180 additional downstream products, with steel- and aluminium-intensive machinery making up the bulk. Construction equipment, vehicle parts, industrial machinery, and metal fittings are explicitly named in the Commission Q&A.
The headline reads as a tariff cliff. The arithmetic on the ground is much smaller. A 6-tonne telehandler carries roughly 3.5 tonnes of embedded steel. At the 2028 punitive mark-up of 30 percent applied to the Chinese steel default value of 1.84 tCO2 per tonne for tubes and structural sections, and at the forecast EU ETS price of EUR 90-110 per certificate, the CBAM cost lands at EUR 400-700 per unit imported. For a machine that costs EUR 35,000-50,000 FOB plus freight, that is roughly 1-2 percent of landed cost. It is not nothing. It is also not the cost gap that decides procurement.
The price delta to a comparable EU-built telehandler such as the Manitou MLT 625, JCB 525-60, or Merlo TF35.7 runs EUR 15,000-25,000 per unit. CBAM 2028 narrows the gap by a few hundred euros. It does not close it. EU manufacturers face their own ETS pass-through inside Europe, which the CBAM benchmark adjustment is specifically designed to offset (the 97.5 percent CBAM factor for 2026 already reflects that internal cost being baked in).
What CBAM 2028 actually changes for you depends on three factors: the Chinese-content steel volume in your unit, the date your order is locked, and whether your contract structure pushes CBAM compliance cost to the supplier or to your importing entity. The definitive period that started 1 January 2026 charges certificates on covered goods (cement, iron and steel, aluminium, fertilisers, electricity, hydrogen). Construction equipment is not covered in 2026 or 2027. Orders shipped before 1 January 2028 land at zero CBAM cost on the machinery line.
That is the buying window. Orders placed in 2026 for delivery in 2026-2027, or 2026-locked contracts for staggered delivery through end-2027, fall entirely outside the construction-equipment CBAM scope. From 2028 onward the per-unit certificate cost ramps under the existing mark-up schedule (10 percent in 2026, 20 percent in 2027, 30 percent from 2028 for in-scope steel today).
## 6-Tonne Telehandler Landed Cost, Rotterdam Delivery
| Source | FOB (EUR) | Freight | EU duty | VAT (DE 19%) | CBAM 2026 | CBAM 2028 (est.) | Landed 2026 | Landed 2028 |
|—|—|—|—|—|—|—|—|—|
| Manitou EU-built (MLT 625) | 56,000 | 0 | 0% | 10,640 | 0 | via ETS | 66,640 | ~67,500 |
| China-direct, standard | 38,000 | 1,800 | 0% | 7,562 | 0 | n/a | 47,362 | n/a |
| China-direct, post-2028 | 38,000 | 1,800 | 0% | 7,562 | n/a | ~600 | n/a | 47,962 |
| China-direct, Stage V certified | 41,000 | 1,800 | 0% | 8,132 | 0 | ~650 | 50,932 | 51,582 |
Cost gap to EU-built: EUR 19,000 in 2026; roughly EUR 19,500 in 2028 once CBAM applies. The relative procurement advantage of factory-direct China supply moves by under 3 percent.
## Decision Read by Buyer Type
**Short-term fleet additions (orders 2026 to 2027 delivery).** No CBAM cost on construction equipment, period. Order books on factory-direct supply remain at 2026 landed-cost arithmetic.
**Multi-year rental fleet planning (3-7 year horizon).** Build CBAM into 2028+ unit acquisition cost at roughly EUR 400-700 per unit, depending on machine class. Use the 2026-2027 window to front-load purchases on heavier-class machines (12 tonne+ rotating models) where embedded steel volume pushes the CBAM hit higher.
**Large public tenders (German Autobahn, French Plan de Relance, Italian PNRR).** Specify pre-2028 contract date in the procurement schedule to lock in current landed-cost arithmetic. Public projects with mandatory carbon disclosure are likely to apply CBAM cost in winning-bid evaluation from 2028.
**Buyers shipping to non-EU destinations.** No CBAM exposure. The construction-equipment CBAM applies only to imports into the EU customs territory.
## Trade-Offs
EU-built telehandlers carry CE marking that already covers Stage V emissions, EN 1459 lift testing, and full EU machinery directive compliance. China-direct supply at full Stage V spec carries the same documentation, at a premium of EUR 2,500-4,000 per unit over non-Stage V configurations. For EU-bound buyers, the Stage V China-direct route is the apples-to-apples compare against EU OEM pricing, not the non-compliant export variant.
Mills that supply factory-direct manufacturers using EAF or partial scrap recycling will price the CBAM exposure lower than blast-furnace-only suppliers. Factory-direct suppliers who can publish CBAM-compliant emissions documentation by Q3 2026 capture the lower default-value bucket once the construction-equipment scope kicks in.
The structural risk for buyers locked into long EU sourcing strategies runs opposite to the headline: EU brands raise prices each year, the EU steel ETS continues to compress free allocations, and the cost arithmetic of factory-direct supply with CBAM-compliant documentation widens its lead through 2030.
## What to Do This Quarter
Lock the 2026 ordering window for any machines slated for 2026-2027 EU delivery. For 2028+ delivery slots, request a supplier-side CBAM cost commitment based on the supplier’s specific mill mix and emissions documentation, not the EU default value. Request a comparison: 2026 China-direct landed cost versus 2028 CBAM-adjusted China-direct landed cost versus 2028 EU OEM list, for your machine class and EU destination port.
## Sources
– [S&P Global – Brussels to expand CBAM to downstream steel, aluminum](https://www.spglobal.com/energy/en/news-research/latest-news/energy-transition/121625-brussels-to-expand-cbam-to-downstream-steel-aluminum-overhaul-power-import-rules)
– [European Commission – Commission strengthens the Carbon Border Adjustment Mechanism](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_3088)
– [China Briefing – EU CBAM 2026 China Manufacturing Impact](https://www.china-briefing.com/news/eu-cbam-2026-china-based-manufacturing-impact-investment-strategy/)
– [Carboneer – CBAM enters the definitive period: key regulatory updates and scope extension](https://carboneer.earth/en/2025/12/cbam-definitive-period-scope-extension/)