Publications
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...
From Process to Product: A Fix to the Allocation of Free Emission Permits to Industry
On 18 April 2023, Sandbag presented to the European Commission’s Expert Group on Climate Change Policy a proposal for reforming the granting of free emission permits to industry under the bloc’s carbon market. Our proposal aims to incentivise the switch to lower...
The Net Zero Industry Act: all industry, no net zero
The European Commission’s proposal for a Net-Zero Industry Act (NZIA) as part of the Green Deal Industrial Plan purports to boost the European green transition whilst decreasing dependence on third countries. But does what sounds like a win-win for industry and the...
The European Hydrogen Bank: a recipe for competitive distortion
Last Thursday, the European Commission published its Communication on the European Hydrogen Bank set to accompany the Net-Zero Industry Act, the legislative proposal for which was published on the same day. The Bank will be an instrument aimed to domestically...
EU Criteria for Green Hydrogen: How They Could Increase Relience on Thermal Power and Hijack the Energy Transition
On February 13th 2023, the European Commission released two pieces of legislation to provide criteria defining renewable hydrogen products. The so-called Delegated Acts matter because they set out how to comply with other regulations under review which will force ships, aircraft and heavy industry to use a minimum content requirement of the fuel, such as the Renewable Energy Directive, REFuelEU Aviation and FuelEU Maritime.
Mind the Scrap: Ignoring Embedded Emissions Puts the CBAM at Risk
Sandbag’s submission to DG TAXUD’s Informal Expert Group on the Analytical Methods for the Monitoring, Reporting, Quantification and Verification of Embedded Emissions in Goods under the Scrope of the Carbon Border Adjustment Mechanism (CBAM). According to notes...
Lost opportunity of carbon market reform leaves a lot to fix in ancillary laws
Sandbag warns that EU carbon market reforms raise ambition but fail to fix structural flaws: free allocation is phased out too slowly, CBAM coverage remains partial, benchmarks still reward polluting processes, and circularity is sidelined-risking inefficiency, distortions, and missed decarbonisation opportunities
What’s new in the ETS trilogues? Benchmark revisions (or not!)
This weekend, the European Commission, Parliament, and Council are set to finalise an important reform of the EU’s carbon market in the final round of their “trilogue” (trilogues are informal tripartite meetings on legislative proposals between representatives of...
An Export Solution for a Faster CBAM Phase-in
A Carbon Border Adjustment Mechanism (CBAM) has been proposed by the European Commission as an alternative to the measures under the EU ETS that currently address the risk of carbon-intensive industries relocating to countries with no carbon pricing (carbon...
Spend Smarter: A bit of advice on climate innovation financing
Report | Spend Smarter: A bit of advice on climate innovation financing Download the report Currently, most EU-managed climate innovation subsidies go to innovation (through the Innovation Fund). The EU’s Innovation Fund, launched in 2020, is one of the world’s...
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