About Us
What is Sandbag?
We are a think tank that promotes more effective climate policies from an environmental and economical point of view. We believe that, for some sectors, carbon pricing can be very effective if designed correctly.
Our name Sandbag symbolises the coordinated action people take to protect themselves and others in the face of extreme weather events. Likewise, we work to unite stakeholders to protect the environment, society, and economy from the risks of ineffective climate action.
We are a Belgian not-for-profit organisation (Association Sans But Lucratif – ASBL). Any financial surplus is reinvested into Sandbag. Our registration number is 0707.935.890.
Our Story
- 2008: Sandbag was founded in London, to reveal flaws in the EU Emissions Trading System (ETS) and develop solutions for its surplus of carbon allowances.
- 2013: Opening of an office in Brussels, to reinforce our influence on EU policy.
- 2018: Sandbag officially became a non-profit organisation under Belgian law (ASBL).
- 2019: After Brexit, the UK-based entity was renamed Ember, while Sandbag focused only on EU climate policy.
Since 2019, we have strengthened our focus on EU decarbonisation policies, leveraging our expertise in carbon markets and data analysis.
Today, our data tools and technical insights are trusted by policymakers and media – across Europe and beyond.
Our Vision
Fighting climate change is too big a task to leave to any one group alone. Lasting solutions require shared efforts, from industries that produce emissions and the policymakers that regulate them, to consumers and citizens who drive demand. Progress happens when all sides move together.
Climate policies should make polluting goods more expensive, and low-carbon alternatives more competitive – creating the right incentives across the economy for both producers and consumers. While investment in new technologies is essential and can accelerate decarbonisation, it works best alongside robust carbon pricing: unlike subsidies alone, a cap on emissions guarantees that targets are met regardless of how quickly new technologies scale.
Climate policies should discourage – not protect – unsustainable economic activities. The free allocation of emission permits in the EU Emissions Trading System sets wrong incentives and should be abolished. To avoid unfair competition from parts of the world without carbon pricing, the EU Carbon Border Adjustment Mechanism ensures the phasing out of free emission permits.
Our Expertise
Our specialists have over 20 years of experience working on carbon markets, industry, finance and climate policy. With a strong understanding of the market and its price effects, we bring a unique perspective to climate policies and consistently think ahead of the curve. For example, we warned against the so-called “CBAM scrap loophole” as early as February 2023, before the issue was picked up by the Draghi report (September 2024) and addressed in December 2025 by a Commission proposal to include pre-consumer scrap into the scope of the CBAM.
Through quantitative and qualitative research, interactive policy simulation tools, and targeted advocacy, we promote policies that drive impactful, cost-effective emissions reductions in the EU and beyond.
Our Advocacy
How we help shape policy: We contribute to European Commission Expert Groups and feed into the legislative process by responding to targeted stakeholder surveys, public consultations and calls for evidence. We meet and exchange with policymakers at the EU Commission, EU Parliament, and Member States level. We initiate and contribute to joint actions with civil society and private stakeholders, including joint meetings with and letters to politicians. We speak out at public events, build coalitions with progressive private sector stakeholders, and raise awareness through media and social media.
Don’t Ruin the EU ETS! Joint NGO Letter to the European Council
Ahead of the March European Council meeting, we’ve joined a group of 35 civil society organisations calling on EU leaders to protect the integrity of the EU Emissions Trading System.
The EU CBAM gives a boost to Algeria’s iron exports
Sandbag’s brief assesses how the EU Carbon Border Adjustment Mechanism (CBAM) may affect Algeria’s iron and steel exports. It finds that although Algeria’s overall exposure to CBAM is limited, rising EU carbon costs are likely to increase EU market prices, with implications for the revenues and competitiveness of Algerian exports.
ICC reform and expansion risks diverting ETS revenues from real climate action
Sandbag and 14 other organisations urge the European Commission to reform, not expand, the ETS Indirect Cost Compensation scheme — warning that current proposals risk diverting climate funding into untargeted fossil subsidies.
Sandbag’s feedback to the call for evidence on the Circular Economy Act
Sandbag welcomes the Circular Economy Act (CEA) as an important step to accelerate the transition to a circular economy in the EU. Progress in this area has been slow and this act is sorely needed to address systemic issues holding back circularity, including the current fragmented approaches across Member States.
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.
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).
Strengthening the CBAM — by default
The consultation aims to address concerns that the CBAM has loopholes that could distort competition between products manufactured in the EU (covered by the EU ETS) and imported goods. Our response sets out proposals for how the design of the CBAM could be improved in these regards.
Extending the CBAM to indirect emissions
The European Commission is considering amending the Carbon Border Adjustment Mechanism (CBAM) to include indirect emissions of CO2 from the use of electricity in the manufacturing of CBAM-covered goods.
The EU ETS at a Crossroads
Sandbag’s latest submission to the EU ETS and Innovation Fund consultation calls for clearer rules on free allocation, stronger criteria for funding innovation, and safeguards against misleading carbon accounting practices.
Our Research
We conduct quantitative and qualitative analyses on decarbonisation technologies and policies.
Based on our research, monitoring of EU legislation, policy and data analysis, as well as simulations thereof, we create technical briefs, research notes, in-depth reports, and derive evidence-based policy recommendations to improve the EU’s climate policies.
Chemicals and CCS/U: Exploring the role of carbon capture in the sector’s transition to ‘circularity’
This technical brief explores the potential role of carbon capture, storage and utilisation (CCS/U) for Europe's chemicals sector.
We find that CCS/U will be necessary in Europe’s chemicals sector, but only to a limited extent in targeted applications.
The EU CBAM gives a boost to Algeria’s iron exports
Sandbag’s brief assesses how the EU Carbon Border Adjustment Mechanism (CBAM) may affect Algeria’s iron and steel exports. It finds that although Algeria’s overall exposure to CBAM is limited, rising EU carbon costs are likely to increase EU market prices, with implications for the revenues and competitiveness of Algerian exports.
CBAM and Fertiliser Inflation in 2026: The facts behind the numbers
Estimates suggesting that the EU’s Carbon Border Adjustment Mechanism (CBAM) could increase fertiliser prices by up to 30% have brought a central question into focus: how significant is the inflationary impact likely to be?
The CBAM dividend for Namibia and Ghana
This research note shows that Namibia and Ghana are likely to benefit from the CBAM, as EU price increases linked to the EU ETS outweigh CBAM fees under current exports. It also sets out transparent transformation scenarios, based on announced industrial projects, to show how expanded and lower-emissions production could further increase export revenues over time.
Steel labelling: Beyond the sliding scale
As EU policymakers debate how to certify low-carbon steel, Sandbag’s new briefing analyses the “sliding scale” method — and outlines why it may hinder rather than help decarbonisation. A new model is proposed based on product-specific benchmarks, multi-tier ratings, and circularity incentives.
Chemicals in the CBAM: Time to step up
Sandbag’s latest brief explains why the EU CBAM must be expanded to cover key chemical value chains. With chemicals and refinery products responsible for 30% of industry emissions, phased inclusion is critical to prevent carbon leakage and phase out free allowances.
Scrap Steel at Sea: How ship recycling can help decarbonise European steel production
As Europe seeks to decarbonise its steel industry, a new Sandbag report highlights an overlooked solution: high-quality scrap steel from retired ships. With up to 15 million tonnes of certified scrap available annually, ship recycling could meet 20% of EU steel scrap demand — if policy gaps are addressed.
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.
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.
Our Tools
The impacts of policy options are sometimes difficult to estimate, especially when several parameters can be combined. We publish visual tools and simulators to better understand policies and different combinations of policy design options.
Our Supporters
Our work is supported by foundation grants and individual donations from those who share our commitment to advancing evidence-based climate policies. Occasionally, we undertake consultancy work that aligns with our mission to drive efficient emissions reductions.
Past supporters include the European Climate Foundation, the Energy Foundation China, the Konrad Adenauer Stiftung, the Environmental Defense Fund, the French Ministry of the Environment and the German Society for International Cooperation (GIZ).
We thank all our supporters for enabling our efforts to strengthen EU climate policy and, in doing so, contributing to the fight against climate change.
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