Building Smarter Climate Policy
We are a think tank conducting data-driven and evidence-based advocacy to improve climate policy in the EU and beyond.
Don’t Ruin the EU ETS! Joint NGO Letter to the European Council
Ahead of the March European Council meeting, we’ve joined a group of 35 civil society organisations calling on EU leaders to protect the integrity of the EU Emissions Trading System.
Chemicals and CCS/U: Exploring the role of carbon capture in the sector’s transition to ‘circularity’
This technical brief explores the potential role of carbon capture, storage and utilisation (CCS/U) for Europe's chemicals sector.
We find that CCS/U will be necessary in Europe’s chemicals sector, but only to a limited extent in targeted applications.
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
Estimates suggesting that the EU’s Carbon Border Adjustment Mechanism (CBAM) could increase fertiliser prices by up to 30% have brought a central question into focus: how
significant is the inflationary impact likely to be?
The CBAM dividend for Namibia and Ghana
This research note shows that Namibia and Ghana are likely to benefit from the CBAM, as EU price increases linked to the EU ETS outweigh CBAM fees under current exports. It also sets out transparent transformation scenarios, based on announced industrial projects, to show how expanded and lower-emissions production could further increase export revenues over time.
Steel labelling: Beyond the sliding scale
As EU policymakers debate how to certify low-carbon steel, Sandbag’s new briefing analyses the “sliding scale” method — and outlines why it may hinder rather than help decarbonisation. A new model is proposed based on product-specific benchmarks, multi-tier ratings, and circularity incentives.
Chemicals in the CBAM: Time to step up
Sandbag’s latest brief explains why the EU CBAM must be expanded to cover key chemical value chains. With chemicals and refinery products responsible for 30% of industry emissions, phased inclusion is critical to prevent carbon leakage and phase out free allowances.
Scrap Steel at Sea: How ship recycling can help decarbonise European steel production
As Europe seeks to decarbonise its steel industry, a new Sandbag report highlights an overlooked solution: high-quality scrap steel from retired ships. With up to 15 million tonnes of certified scrap available annually, ship recycling could meet 20% of EU steel scrap demand — if policy gaps are addressed.
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.
Sandbag’s feedback to the call for evidence on the Circular Economy Act
Sandbag welcomes the Circular Economy Act (CEA) as an important step to accelerate the transition to a circular economy in the EU. Progress in this area has been slow and this act is sorely needed to address systemic issues holding back circularity, including the current fragmented approaches across Member States.
Our Impact
March 2026: European Court of Auditors cited Sandbag in its report on the Innovation Fund
Sandbag’s analysis was cited in the European Court of Auditor’s special report on the innovation fund, published on 23 March, 2026.
Citing Sandbag, the report notes that the rating system rewards over-optimistic estimates. As this methodology is used for two of the five award criteria, it is a serious structural flaw.
December 2025: Sandbag analysis cited in the European Commission"s CBAM impact assessment
Sandbag analysis was cited in the European Commission’s CBAM impact assessment published on 17 December 2025. The assessment explicitly recognises risks of CBAM circumvention and reflects policy options Sandbag developed on extending CBAM coverage to uncompensated indirect emissions and downstream goods.
Sandbag’s analysis is cited in the Commission’s impact assessment at the following locations:
-
Impact Assessment – Part 1:
pp. 7 and 14
https://taxation-customs.ec.europa.eu/document/download/71d4f753-4a2d-4367-bb10-c1967cb7f28d_en?filename=SWD_2025_988_1_EN_impact_assessment_part1_v4.pdf -
Impact Assessment – Part 2 :
p. 6
https://taxation-customs.ec.europa.eu/document/download/61b0d225-8b3f-42e0-996a-58c228a4bae7_en?filename=SWD_2025_988_1_EN_impact_assessment_part2_v4.pdf
These policy options were set out in Sandbag’s response to the Commission’s public consultation on CBAM reform, published as Strengthening the CBAM by default (August 2025).
December 2025: Commission CBAM Review reflects Sandbag proposal on uncompensated indirect emissions
In its review of the Carbon Border Adjustment Mechanism published in December 2025, the European Commission sets out technical options to extend CBAM coverage to indirect emissions.
The review considers an option to cover only the share of indirect emissions not compensated under existing electricity compensation schemes, including by using Member State data on actual compensation payments to calculate the uncompensated share (p.48). This approach reflects a proposal developed by Sandbag during the CBAM review process.
Sandbag set out this proposal in its analysis on extending CBAM to indirect emissions, submitted to the Commission earlier in 2025.
Read Sandbag’s analysis:
https://sandbag.be/2025/08/01/why-the-cbam-should-cover-indirect-emissions/
Read the European Commission’s CBAM Review Report:
https://taxation-customs.ec.europa.eu/document/download/3903da9d-44fd-4508-8915-f27ef25fe033_en?filename=Review%20Report_0.pdf
Our Work
EU ETS
We fight to make the EU Emissions Trading System more effective at driving the decarbonisation of industry, aviation and shipping.
CBAM
We advocate for a fast and comprehensive Carbon Border Adjustment Mechanism to replace the free allocation of emissions allowances under the EU ETS, which is a major flaw of the carbon market.
Industry
Designing policy instruments requires expertise on the sectors and technologies they cover. We have built expertise in steelmaking, aluminum, construction, hydrogen, electrification, and circularity.
Our Interactive Tools
The impacts of policy options are sometimes difficult to estimate, especially when several parameters can be combined. We publish visual tools and simulators to better understand policies and different combinations of policy design options.
Join us in building smarter climate policies!
WHAT WE DO
TOOLS
PUBLICATIONS
NEWSLETTER
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Sandbag is a not-for-profit (ASBL) organisation registered in Belgium under the number 0707.935.890.
EU transparency register no. 277895137794-73.
VAT: BE0707935890.