Free allocation has long been used to address carbon leakage under the EU ETS, but it has key limitations. It only covers emissions up to benchmark levels, fails to reward cleaner EU producers, and forfeits auction revenues that could support decarbonisation. It also creates perverse incentives by making high-emission goods artificially cheap.
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.
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’.
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...
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.
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...
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...
Sandbag warns that EU carbon market reforms raise ambition but fail to fix structural flaws: free allocation is phased out too slowly, CBAM coverage remains partial, benchmarks still reward polluting processes, and circularity is sidelined-risking inefficiency, distortions, and missed decarbonisation opportunities
A Carbon Border Adjustment Mechanism (CBAM) has been proposed by the European Commission as an alternative to the measures under the EU ETS that currently address the risk of carbon-intensive industries relocating to countries with no carbon pricing (carbon leakage),...
The reform of the European carbon market (ETS, for Emissions Trading Scheme) and related Carbon Border Adjustment Mechanism (CBAM) will define the future of the circular economy for years to come. These two files are in the final step of the legislative procedure, the...