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Carbon Border Adjustments in the EU: who, what, when, why and how?

The public consultation on the Carbon Border Adjustment Mechanism is coming to a close. The European Commission has been collecting stakeholder opinions on one of its most talked-about policy projects: ensuring that imports to the EU are subject to the same carbon price as domestic EU products. While the “CBAM” has been the buzzword on everyone’s lips for the past few months, Sandbag has been working on this topic for over a year, as part of our research around the reform of the EU ETS. We added our voice to the public consultation, responding to the Commission’s questionnaire and submitting a detailed position paper covering the big questions around the CBAM.

28 October 2020

Who? What sectors should the CBAM apply to? What countries? What will the consequences be for EU producers availing of free allocation?

The CBAM should prioritise emissions-intensive sectors covered by the EU ETS, like cement, steel, electricity, plastics and ammonia. It should be applied to all the EU’s trade partners, with special provisions for those who have their own form of carbon pricing. Free allowances will need to be abolished as the CBAM is introduced.

What? Should the CBAM apply to direct or indirect emissions? To all products or only emissions-intensive commodity materials?

For the sake of administrative simplicity and for maximising the climate impact of the CBAM, it should focus on direct emissions from very emissions-intensive commodity materials. Covering all imports would be very challenging and carbon leakage is not a major risk for more complex products.

When? A rapid introduction or a gradual phase-in period? How will this interact with the phases and planned reforms of the EU ETS?

The CBAM should be introduced as soon as possible, along with timely reform of the EU ETS that sees an end to free allocation and aligns the ETS cap to the net-zero 2050 goal.

Why? What is the real aim of the CBAM? To prevent carbon leakage, to encourage global climate ambition or to raise EU revenues?

To be compatible with the WTO rules, the CBAM should focus on improving EU domestic climate policy through preventing carbon leakage. Influencing the policies of other states and raising revenues may be beneficial side effects but should not be the main goal.

How? What will the mechanism look like? How will it interact with the EU ETS? How to estimate the carbon content of imported products?

The CBAM should be based on the EU ETS price, either by bringing imports under the EU ETS or by having a border tariff that closely mirrors the EU ETS price. Depending on the measure chosen and the details of its implementation, the CBAM could impact the supply of EUAs or change the carbon price. The carbon content of products should be estimated based on the average EU carbon intensity per product, taking into account differing production methods.

Image credits: CHUTTERSNAP on Unsplash