Carbon Border Adjustment Mechanism: MedTech Europe responds to the European Commission public consultation

Posted on 04.09.2025

This summer, the European Commission consulted stakeholders on the upcoming review of the CBAM Regulation considering its extension to downstream products, anti-circumvention measures and rules for the electricity sector. In its response, MedTech Europe outlines the sector specificities to be taken into account in the further proceedings.

MedTech Europe shares the general motivation of preventing carbon leakage in support of fair carbon pricing as long as global climate ambitions differ. However, at this stage, MedTech Europe has no evidence of carbon leakage in the sector due to difference in global carbon cost that would in our view justify the inclusion of medical technologies or components used in the manufacturing and assembly of medical technologies in Europe in the scope of an extended CBAM.

We appreciate the current efforts towards simplification, which should be maintained and strengthened, including the de minimis threshold and use of default values for emission calculation. However, we still observe significant challenges regarding the technical feasibility of implementing CBAM on highly complex products, such as medical technologies and their supply chains that can be up to 30 tiers from materials to the final device.

It is not uncommon for routinely used devices to have hundreds and thousands of different components, including iron-, steel and aluminium intense components. 

Please see our full considerations on the CBAM and health interface here:  MedTech Europe’s response to the EC public consultation on CBAM.

For further information contact: Sigrid Linher, Director Sustainability and Environment