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: CBAM and Outreach
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’.