The EU’s Carbon Border Adjustment Mechanism (CBAM) aims to ensure that imported goods face the same carbon costs as those produced in Europe.
As CBAM enters its next phase, the European Commission asked for input on three areas:
- Article 7 – Emissions reporting
- Article 31 – Adjustment to take account of free allocation
- Article 9 – Carbon prices paid in third countries
Sandbag responded to each consultation, highlighting risks that could weaken CBAM’s impact and offering practical solutions.
Our main recommendations
- Article 7 (Emissions reporting): Avoid resource shuffling by using induced emissions and systematic default values for steel, aluminium, cement, and electricity imports.
- Article 31 (adjustment for Free allocation): Move to product-based free allocation, ensuring equal treatment between EU and imported goods.
- Article 9 (Carbon price paid abroad): Ensure deductions only apply where carbon prices are paid for the production of goods, taking into account all support received by the production plant even not for carbon.
Related publications
Aug 6th 2025
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More on the Carbon Border Adjustment Mechanism
The EU CBAM gives a boost to Algeria’s iron exports
Sandbag’s brief assesses how the EU Carbon Border Adjustment Mechanism (CBAM) may affect Algeria’s iron and steel exports. It finds that although Algeria’s overall exposure to CBAM is limited, rising EU carbon costs are likely to increase EU market prices, with implications for the revenues and competitiveness of Algerian exports.
CBAM and Fertiliser Inflation in 2026: The facts behind the numbers
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significant is the inflationary impact likely to be?
The CBAM dividend for Namibia and Ghana
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