We’re a non-profit climate change think tank which uses data analysis to build evidence-based campaigns on climate policy
We focus on EU policies such as the EU Emissions Trading Scheme, carbon border adjustment mechanisms and emissions reductions in industrial sectors. We believe in Europe’s ability to lead climate action by example and use its large market and ability to stimulate technological competition as an incentive for others to follow. But we’re also aware of the risk that Europe might fail to deliver on its own pledges, which is why we want to get EU climate policy right.
Our Work
Carbon Pricing
Our accomplishments on Carbon Pricing
Industry
Our policy recommendations on EU industry
CBAM
Our work on the Carbon Border Adjustment Mechanism
Data Tools
Explore all of our data tools
Financing
Our research on EU funding
Publications
The EU CBAM: a two-way street between the EU and Africa
The Carbon Border Adjustment Mechanism CBAM is often misunderstood as a trade policy whereas it is actually a climate policy. Its only objective, as stated in Article 1 of the CBAM Regulation, is to replace the current system of free allocation of emission allowances to EU-based manufacturers under the EU carbon market.
Electrification or electrical decarbonisation? We need both!
We agree with the European Commission’s general diagnosis that increasing the share of electricity in overall energy consumption is necessary to achieve deep decarbonisation. However, it is not sufficient. If overall energy use increases, or if electricity generation does not decarbonise rapidly, then electrification may fail its decarbonisation role.
Sandbag’s Response to the CBAM Calls for Evidence
Sandbag has submitted responses to the EU’s CBAM calls for evidence, addressing emissions reporting, adjustment for free allocation, and carbon prices paid abroad. We highlight risks such as loopholes and unequal treatment, and propose practical solutions to strengthen CBAM’s effectiveness and fairness.
CBAM impact on US trade: an analysis
Sandbag’s September 2025 research note explores the impact of the EU’s CBAM on US exports. It finds that even with expanded scope, the financial impact remains marginal, and US carbon pricing could turn net costs negative.
The EU CBAM: A Two-Way Street to Climate Integrity?
Supported by the Konrad-Adenauer-Stiftung, Sandbag’s report examines the impact of the EU’s Carbon Border Adjustment Mechanism (CBAM) and the gradual removal of free allowances on third-country exporters. The joint implementation is expected to raise production costs for both EU and non-EU producers, leading to higher prices for CBAM-covered goods in the EU. Moreover, some exporters may reduce CBAM liabilities through resource shuffling, potentially increasing their profit margins.
State Aid for Indirect Carbon Costs: Reform before extending!
Sandbag responds to the EU’s consultation on State aid for Indirect Carbon Costs (ICC), calling for targeted reforms to better support clean electricity, avoid windfall profits, and align with the Carbon Border Adjustment Mechanism (CBAM).
TESTIMONIALS
Sandbag is recognised as a top global climate think-tank
Mundo Matogné. Rue d’Edimbourg 26, Ixelles 1050 Belgium. Sandbag is a not-for-profit (ASBL) organisation registered in Belgium under the number 0707.935.890. EU transparancy register no. 277895137794-73. VAT: BE0707935890










