Publications
Explore our evidence-based research and policy recommendations!
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.
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.
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.
This free allocation system has been in place for industrial processes ever since the market started in 2005 and has led to stagnating emission intensity levels for EU industry. For example, the emission intensity of the EU steel sector has practically not changed in the last 18 years!
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.
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.
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