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Comité Européen de l'Outillage e. V.

CEO

Representing the interests of the European tool industry consisting of - Handtool Manufacturers - Length Measuring Tool Manufacturers - Construction Fixings Manufacturers with official organisations and authorities both, inside and outside Europe and with the public. - Providing any information for the European tool manufacturers, which are of major relevance for the companies. - Providing statistical information for the member companies, enabling them to analyse their actual situation in business. - Maintaining regular contacts among the member companies for exchange of experience and information.

Lobbying Activity

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

24 Sept 2025

The European Tool Association (CEO) welcomes the opportunity to contribute to the call for evidence on the CBAM methodology. While we support CBAM as a tool to prevent carbon leakage and ensure fair competition, it leaves a critical gap in its current scope. CEO strongly calls on the European Commission to include downstream products under CBAM. At the same time, indirect emissions embedded in downstream products must be accounted for as well, as these emissions account for a large share of total emissions in these products and would otherwise not be subject to CBAM. While we acknowledge the simplifications introduced by the recent Omnibus package, it is important to ensure a level-playing field with non-EU producers by including indirect emissions in the CBAM calculation methodology. Please refer to the attached paper for further details.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

21 Aug 2025

The European tool industry strongly welcomes the European Commission´s initiative to consider the extension of CBAM to downstream products. Our industry is under growing pressure due to its exclusion from the Carbon Border Adjustment Mechanism (CBAM). Although CBAM aims to prevent carbon leakage and ensure fair competition, hand tools, power tool accessories and measuring tools remain outside its scope, despite their heavy reliance on carbon-regulated materials like steel. This exclusion creates a regulatory imbalance, meaning that EU manufacturers face higher input costs due to carbon pricing, while non-EU competitors can export finished tools made with cheaper, high-carbon materials without equivalent obligations once the definitive regime of CBAM is in place. We therefore call on the European Commission to include downstream products such as hand tools, power tool accessories and measuring tools under CBAM. In addition, it is of key relevance to simplify the reporting mechanism of CBAM while also taking into account the energy intensity of processing of steel and aluminum into downstream products. A practical proposal for fair and effective Carbon Pricing in CBAM would build on a standardized fixed carbon price per customs tariff code, based on average emissions factors that reflect the typical production processes, material composition, and transport emissions associated with each product group. This system could function through a centralized CBAM reference table maintained by the European Commission or a designated authority. Importers would not need to conduct individual carbon footprint calculations. Instead, they would identify the applicable tariff code for the imported good, which is already a standard requirement in customs declarations, and determine the corresponding CBAM levy by consulting the CBAM reference table. For further details, please refer to our Position Paper attached the consultation.
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Meeting with Stefan Fuehring (Head of Unit Secretariat-General)

2 Jul 2025 · Carbon Border Adjustment Mechanism (CBAM); implementation of the Construction Products Regulations (CPR); external trade

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union)

2 Jul 2025 · CBAM downstream extension and circumvention risks

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

1 Jul 2025 · CBAM