Our main messages:
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Simplify the EU ETS by phasing out free allocation
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Aviation: put a seat belt on EUA supply
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Free allocation: switch from process to products
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Link indirect cost compensation to carbon-free electricity only
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Reform the Innovation Fund to:
– Better assess the carbon footprint of electricity use
– Reserve grants to technology risk
– Reserve scale-up subsidies to poorly capitalised sectors -
Market Stability Reserve: reduce the reinjection rate as well as thresholds
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Keep carbon removals out of the ETS
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Do not shift CCU carbon accounting down value chains
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Limit linking with other ETS
Read our responses on the European Commission’s website:
Read more on the EU ETS and climate financing
ICC reform and expansion risks diverting ETS revenues from real climate action
Sandbag and 14 other organisations urge the European Commission to reform, not expand, the ETS Indirect Cost Compensation scheme — warning that current proposals risk diverting climate funding into untargeted fossil subsidies.
State Aid for Indirect Carbon Costs: Reform before extending!
Sandbag responds to the EU’s consultation on State aid for Indirect Carbon Costs (ICC), calling for targeted reforms to better support clean electricity, avoid windfall profits, and align with the Carbon Border Adjustment Mechanism (CBAM).
Simulating CDR in the EU ETS: The Risks of Premature Integration
The EU’s 2040 climate targets suggest integrating carbon removals into the ETS — but at what cost? This report uses Sandbag’s simulator to assess whether the risks of premature CDR integration outweigh the benefits.




