Publications
CBAM DRI loophole requires new free allocation reform
We took part in a targeted survey run by the European Commission’s DG TAXUD on methodologies used to calculate embedded emissions and the rules for adjusting CBAM obligations alongside free allocation under the ETS. Our proposal: free allocation should be reformed to close the ‘DRI loophole’.
Feedback on the EU Commission’s draft methodology for low-carbon hydrogen
For ‘low carbon’ hydrogen to truly make a positive contribution to Europe’s transition to climate neutrality, the safeguards put in place must be meaningful. Unfortunately, this does not appear to be the case in this draft delegated act.
Metallurgical flexibility: Enabling the aluminium and steel sectors for demand response
Electrification and flexibility are critical to decarbonising both industrial and electricity systems. But what happens when we combine the two? Industrial flexibility will play an increasingly important role as industry moves towards electrification.
A closer look at 2023 emissions: steelmaking caused a quarter of industry pollution
This brief analyses 2023 emissions under the EU Emissions Trading System (EU ETS), using the latest data available from the EU Transaction Log (EUTL) . It particularly focuses on the iron and steel sector.
Feedback on the inclusion of permanent CCU in the EU ETS
Steel and CCS/U: Decarbonisation potential, costs, and bottlenecks
Carbon capture, storage and/or utilisation (CCS/U) technologies are often touted as a ‘catch all’ solution for the decarbonisation of heavy industry, but their effectiveness and relevance vary widely across applications. This new report offers a comprehensive assessment of CCS/U technologies in the context of iron and steel manufacturing in Europe.
Closing the CBAM scrap loophole – A critical move for climate & competitiveness
Supply and demand in the EU ETS: It’s the hydrogen, stupid!
Learn about the supply and demand balance of the EU ETS through the end of its fourth phase in 2030, based on the latest market data and policy parameters. Are the results aligned with the EU’s target of a 55% reduction in emissions?
A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism
Currently, we are in the CBAM transitional period, with negotiations ongoing for its full implementation in January 2026. Learn about the legislative process and the effect of this policy on the EU’s main trade partners, especially China.
CEPS-Sandbag Joint Op-Ed – The EU should lead the green steel race… Or it could be left behind in the dust

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Sandbag is a not-for-profit (ASBL) organisation registered in Belgium under the number 0707.935.890.
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VAT: BE0707935890.