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European Cylinder Makers Associaton

ECMA

The goal of the European Cylinder Makers Association, ECMA, is the safety and technical progress of high pressure gas cylinders.

Lobbying Activity

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

The European Cylinder Makers Association supports the inclusion of CN codes 7311 00 Containers for compressed or liquefied gas, of iron or steel and 7613 00 00 Aluminium containers for compressed or liquefied gas into Regulation 2023/956. Whilst these CN codes are clear for the traditional types of containers, that is gas cylinders, produced by ECMA Members, we wish to ensure that containers using the newer technologies of using composite materials, which may not include, iron, steel or aluminium, are covered. We would like confirmation that CN code 73110090.00, Other containers for compressed or liquefied gas, not for retail packing covers these types of containers. Our concerns are that if they are not included in the CBAM these containers could by-pass this import legislation. ECMA would welcome the opportunity to provide information on containers of composite construction for compressed or liquefied gases to ensure that they are fully covered by CBAM.
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