Sandbag’s August 2025 brief calls for systemic default values to close CBAM loopholes—addressing scrap and cement circumvention, electricity imports, and indirect emissions.
Category: Carbon Border Adjustment Mechanism (CBAM)
Extending the CBAM to indirect emissions
Sandbag’s latest brief outlines why the CBAM must include indirect emissions — and how this would improve climate effectiveness, industrial fairness, and fiscal efficiency.
CBAM extension: Closing the emissions gap
Sandbag’s new position paper urges the European Commission to expand the CBAM horizontally and vertically, addressing loopholes and supporting the phase-out of free allocation.
For a systematic use of default values in the CBAM
The current carbon emissions reporting in the CBAM fails to achieve its goal of replacing free allocations under the EU ETS and undermines its integrity. A systematic default value system would improve the CBAM and safeguard the EU ETS.
CBAM DRI loophole requires new free allocation reform
We took part in a targeted survey run by the European Commission’s DG TAXUD on methodologies used to calculate embedded emissions and the rules for adjusting CBAM obligations alongside free allocation under the ETS. Our proposal: free allocation should be reformed to close the ‘DRI loophole’.
Closing the CBAM scrap loophole – A critical move for climate & competitiveness
This joint op-ed by Norsk Hydro, Alcoa, Bellona Europe and Sandbag was published by Carbon Pulse. The EU’s Carbon Border Adjustment Mechanism (CBAM) was established to extend Europe’s carbon pricing to imported products, aiming to create a level playing field between...
A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism
Currently, we are in the CBAM transitional period, with negotiations ongoing for its full implementation in January 2026. Learn about the legislative process and the effect of this policy on the EU’s main trade partners, especially China.
Feedback on the Draft of the CBAM Implementing Regulation
We welcome the Commission's draft of the CBAM implementing regulation concerning the reporting obligations and provisional methodology for calculating embedded emissions in CBAM goods. However, we have concerns regarding the accounting and monitoring rules applied to...
Mind the Scrap: Ignoring Embedded Emissions Puts the CBAM at Risk
Sandbag’s submission to DG TAXUD’s Informal Expert Group on the Analytical Methods for the Monitoring, Reporting, Quantification and Verification of Embedded Emissions in Goods under the Scrope of the Carbon Border Adjustment Mechanism (CBAM). According to notes...
Lost opportunity of carbon market reform leaves a lot to fix in ancillary laws
On 13 December 2022, the European Commission, Council and Parliament reached a provisional agreement on the Carbon Border Adjustment Mechanism that will partly replace the free allocation of emissions permits to polluters covered by its carbon market. This marks the...