22 October 2026 | Market Trends for the NQC Community
What UK CBAM reform, critical minerals and EUDR policy developments mean for supply chains
This edition of The Briefing covers seven developments linked by regulatory proposals, policy reviews and industry groups’ efforts to influence how rules such as CBAM and EUDR are designed and implemented, all of which are shaping the operating environment for global supply chains.
Key takeaways
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The UK is considering changes to its planned CBAM framework, including product-specific benchmarks, country-specific default values and revised carbon-price relief. Jump to section →
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African governments are encouraging domestic processing of critical minerals, while unreliable and expensive electricity remains a major investment constraint. Jump to section →
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Progress on a potential US-Mexico tariff deal has slowed, leaving the treatment of automotive, steel and aluminium trade under discussion. Jump to section →
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France and Germany have indicated that UK participation in parts of EU automotive policy may depend on alignment with China tariffs and other trade-protection measures. Jump to section →
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Stakeholder engagement remains part of EUDR implementation, with a recent investigation and responses from organisations named in it contributing to the wider debate. Jump to section →
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European industry groups have called for CBAM to cover downstream processed products, arguing that basic-material coverage alone leaves European manufacturers exposed to carbon-cost differences. Jump to section →
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Ghana has proposed a phased approach to restricting unprocessed mineral exports by 2030 as part of a domestic-processing policy. Jump to section →
UK considers reforms to its upcoming CBAM framework
The UK government is considering reforms to its planned Carbon Border Adjustment Mechanism (CBAM), which is due to take effect in January 2027. The proposals would align the UK framework more closely with the European Union’s model and consider extending coverage to additional sectors and indirect emissions.
The initial UK framework relies on global sector averages and direct price deductions. That can result in lower carbon costs than those applied under the EU system. The difference has prompted discussion about high-carbon imports, particularly steel, and about the conditions needed for mutual exemptions between the UK and EU CBAM frameworks.
Official presentation materials indicate that the UK is considering product-specific benchmarks, country-specific default values and changes to carbon-price relief deductions. The proposals are intended to reduce discrepancies between the two systems and limit policy friction between the UK framework and the EU Emissions Trading System (ETS).
African minerals processing drive faces an energy hurdle
African countries are encouraging miners to build refineries and smelters domestically rather than exporting raw minerals. The policy objective is to capture more value locally, develop industrial capacity and increase influence over markets for minerals such as bauxite, lithium, manganese and iron.
Governments are using export restrictions, tax incentives and access to deposits to encourage local processing. Investors including the US International Development Finance Corporation and the Africa Finance Corporation have backed processing projects and indicated plans for further activity.
The constraint is energy. Reliable, affordable electricity is essential to processing, yet shortages and high power costs risk reducing investment or making new facilities commercially unviable. South Africa’s decline in ferrochrome and steel processing illustrates the risk when industrial power is expensive or unreliable.
Progress toward a US-Mexico tariff deal stalls
The United States and Mexico had been moving towards a deal that could reduce US levies on steel, aluminium and automobiles in return for concessions from Mexico. Progress has since slowed because of disagreement over tariffs on vehicles and metals.
US Commerce Secretary Howard Lutnick has opposed significant reductions in the 25% tariff on Mexican automobiles and the 50% levies on steel and aluminium. He has also opposed reductions on finished products made from steel and aluminium. Mexico’s deputy trade minister Luis Rosendo Gutierrez has indicated that negotiations are still making progress, while a US Commerce Department spokesperson said the department remained in dialogue with Mexico.
The uncertainty matters because automotive and industrial supply chains often cross the US-Mexico border several times. Changes in tariff treatment can affect sourcing decisions, production locations, component costs and the viability of cross-border manufacturing arrangements.
UK access to EU car policy may depend on China tariff alignment
France and Germany are willing to include the UK car sector in parts of the EU’s “Made in Europe” public procurement scheme, but reports indicate that UK participation could depend on alignment with EU trade-protection measures, including tariffs on Chinese electric vehicles.
The proposed approach would extend the scheme to European partners that were part of the EU internal market at the start of 2020. UK participation would be linked to alignment with EU trade-protection measures, including tariffs on Chinese electric vehicles, with the details still under discussion.
The discussions also include the future of combustion-engine sales in the EU and preference rules for cars and car parts. The details remain subject to negotiation, agreement by other EU member states and approval by the European Parliament before becoming law.
Investigation examines lobbying around EUDR implementation
Mighty Earth has published an investigation into a reported two-year campaign involving US companies and trade associations during the development and implementation of the EU Deforestation Regulation (EUDR). The investigation reports more than 350 meetings and describes efforts to postpone or weaken the legislation.
The organisations named in the report dispute the characterisation of a coordinated campaign and say their engagement with EU officials raised legitimate concerns around implementation.
The investigation places those claims in the context of two implementation delays and revisions to the Regulation’s original traceability aims. Some former supporters have described the changes as a substantial weakening of the policy. The EUDR is scheduled to come into effect in December, subject to the applicable implementation timetable.
Mighty Earth also reports engagement through the US Congress, the US Department of Agriculture, the Office of the US Trade Representative and the White House, as well as lobbying from Brazil and several EU countries. The organisation has called for greater transparency around lobbying and wider access for civil society.
Industry groups press for CBAM to cover processed products
Eurometal, the European Association of Steel, Pipe and Metal Distributors, and a group of European industry associations and trade unions have called for the EU CBAM to be extended to downstream processed goods.
The signatories argue that covering basic materials without addressing finished and semi-finished products could leave European manufacturers at a disadvantage. Domestic carbon costs are rising while free allowances under the EU ETS are being phased out. If imported processed goods do not face comparable carbon costs, European manufacturers may be exposed to cheaper imports or pressured to relocate production.
The sectors affected could extend well beyond metals. Automotive, construction, engineering, packaging and clean-technology supply chains all use steel and aluminium in downstream products.
The policy question is therefore broader than whether CBAM applies to a particular raw material. It concerns how carbon costs move through the value chain and whether downstream manufacturers can compete while meeting European decarbonisation requirements.
Ghana plans to ban raw mineral exports by 2030
Ghana plans to ban exports of unprocessed minerals by 2030, according to comments from President John Mahama. The policy is intended to capture more value from Ghana’s natural resources, support domestic industrialisation and encourage local processing.
The proposed approach would use legislation, mineral-specific requirements and phased implementation timelines. Ghana has already banned exports of iron scrap and non-ferrous metals, as well as raw gold produced by artisanal and small-scale miners.
The policy forms part of a wider African push to retain more value from mineral resources. Guinea is considering restrictions on bauxite shipments, Zimbabwe is banning exports of lithium concentrate and the Democratic Republic of Congo has imposed limits on cobalt exports.
Sources
- Eurometal — UK considering reforms to its upcoming CBAM framework
- Reuters — Africa’s minerals value-add drive interests investors but faces energy hurdle
- Reuters — Progress toward a US-Mexico tariff deal has stalled
- Financial Times — France and Germany to allow UK to join EU car policy if it aligns on China tariffs
- The Guardian — US corporate lobbyists mounted ‘blitz’ to dilute landmark EU deforestation law
- Eurometal / GMK Center — EU CBAM scope and processed products
- Bloomberg — Ghana plans to ban raw mineral exports by 2030
