Flat Steel in the Free Allocation Regulation

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...

The European Hydrogen Bank Confirms a Blind Support Approach

The Commission has recently published the Terms & Conditions (T&C) for the pilot auction of the European Hydrogen Bank (EHB) taking place on the 23rd of November 2023, in an attempt to meet the ambitious target set in the REPowerEU plan of 10Mt domestically...

Feedback on the Draft of the CBAM Implementing Regulation

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...

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...

Fixing the Innovation Fixation

Joint blog with Carbon Market Watch25 May 2023 Sandbag's feedback to the EC25 May 2023 The EU’s Innovation Fund, launched in 2018, is the EU’s programme for funding cutting-edge low-carbon technologies. To be eligible, projects must be, according to the European...

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...

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 research on the EU ETS and emission allowances, advocating for efficient carbon pricing mechanisms and concrete ways to drive emission reductions.


Exploring the potential of electrification, circularity, and innovative technologies to decarbonise hard-to-abate sectors like steel, aluminium, and cement.


Supporting a strong CBAM to phase out the allocation of free emission allowances, address carbon leakage, and accelerate global climate action.


Our analysis of EU funding initiatives driving climate innovation and industrial decarbonisation. Ensuring revenues from the EU ETS and CBAM are well spent.

Data Tools

Our data visualisation and simulation tools, allowing EU policymakers to gain unique insights and implement informed climate policies.



Sandbag is recognised as a top global climate think-tank

An inspirational idea that promises to make a real and positive difference… and a wonderful opportunity to help sort out the climate mess we’ve all created. Prof. Chris Turney is the author of Ice, Mud and Blood: Lessons from Climates Past
Chris Turney

Professor, University of Exeter

Sandbag is playing a crucial role in making sure that Europe’s cornerstone climate policy actually does its job.
Caroline Lucas

United Kingdom MP

Sandbag… strikes a balance between underlining the merits of the EU ETS and criticising the weaknesses.
Connie Hedegaard

Former European Commissioner

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