Following the revision of the EU Emissions Trading System (ETS) Directive in April 2023, the European Commission was mandated to review the Free Allocation Regulation, which establishes the methodology that calculates the number of free emission allowances for sectors...
Category: EU Emissions Trading System (ETS)
Supply and Demand in the EU ETS: Powering Through the Cap
The reform of the EU’s carbon market and the free allocation regulation is now voted on. The deal was wrapped in December 2022 and was barely different from what the Commission had proposed nearly two years ago and which we had analysed in September 2021. If the...
Free Allocation Needs to Incentivise Circularity for the EU to Reach Net Zero
Open letter: Free allocation needs to incentivise circularity for the EU to reach net zero To: DG CLIMA - Mr Heiko Kunst Chair of the Expert Group on Climate Change Policy Dear Mr Kunst, We are writing to you on behalf of the European steel scrap recycling...
From Process to Product: A Fix to the Allocation of Free Emission Permits to Industry
On 18 April 2023, Sandbag presented to the European Commission’s Expert Group on Climate Change Policy a proposal for reforming the granting of free emission permits to industry under the bloc’s carbon market. Our proposal aims to incentivise the switch to lower...
Lost opportunity of carbon market reform leaves a lot to fix in ancillary laws
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
What’s new in the ETS trilogues? Benchmark revisions (or not!)
This weekend, the European Commission, Parliament, and Council are set to finalise an important reform of the EU’s carbon market in the final round of their “trilogue” (trilogues are informal tripartite meetings on legislative proposals between representatives of the...
An Export Solution for a Faster CBAM Phase-in
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),...
Our concerns regarding ETS and CBAM legislative texts
We have strong concerns regarding the legislative texts on the revision of the Emissions Trading Scheme (ETS) and the Carbon Border Adjustment Mechanism (CBAM), presented by the European Commission, Council and Parliament. All three bodies have proposed to extend the...
2nd ETS trilogue: EU institutions agreed on almost nothing, except on perpetuating free allocation for the steel giants
The second ETS trilogue took place last week on October 11th. Tabled proposals on benchmarks regarding the steel…
European Scrap Steel Floats Away Under Carbon Market Incentives
In 2021, over 14 million gross tonnes of ships were dismantled, with a third owned by European firms and largely scrapped in South Asia. This practice exports high-quality scrap steel that could otherwise support low-carbon steelmaking in Europe. However, EU carbon market rules currently favour carbon-intensive blast furnaces over cleaner electric arc furnaces (EAFs) by allocating more free emissions allowances to the former. This distorts incentives, discouraging investment in greener technologies. Sandbag calls for a faster phase-out of free allowances and a more comprehensive CBAM to promote domestic recycling and decarbonisation.








