Publications
Explore our evidence-based research and policy recommendations!
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?
Sandbag’s latest report examines how the EU’s CBAM will impact third country exporters. While some may reduce costs through resource shuffling, real emissions may remain unchanged — calling for stronger alignment through carbon pricing.
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).
Heat up industry, not the climate!
This position paper analyses the European Commission’s industrial heat auction, highlighting the importance of auction design to ensure electrification reduces emissions without causing unintended increases due to electricity grid dynamics.
Strengthening the CBAM — by default
Sandbag’s August 2025 brief calls for systemic default values to close CBAM loopholes—addressing scrap and cement circumvention, electricity imports, and indirect emissions.
Extending the CBAM to indirect emissions
Sandbag’s latest brief outlines why the CBAM must include indirect emissions — and how this would improve climate effectiveness, industrial fairness, and fiscal efficiency.
New Principles for Steel Labelling: response to the consultation on the Industrial Decarbonisation Accelerator Act
Sandbag’s response to the EU’s Industrial Decarbonisation Accelerator Act sets out four principles to guide green steel labelling schemes, promoting credible standards based on lifecycle emissions and system-wide decarbonisation.
Simulating CDR in the EU ETS: The Risks of Premature Integration
The EU’s 2040 climate targets suggest integrating carbon removals into the ETS — but at what cost? This report uses Sandbag’s simulator to assess whether the risks of premature CDR integration outweigh the benefits.
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.
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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.