Sandbag is a non-profit climate change think tank that uses data analysis and targeted advocacy campaigns to improve EU climate policies
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.
Industry
CBAM
Supporting a strong CBAM to phase out the allocation of free emission allowances, address carbon leakage, and accelerate global climate action.
Climate Financing
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.
Publications
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
We welcome the opportunity to provide feedback on the draft delegated regulation published by the European Commission pursuant to Article 12(3b) of the EU ETS Directive [1] regarding the...
Steel and CCS/U
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...
Closing the CBAM scrap loophole – A critical move for climate & competitiveness
This joint op-ed by Norsk Hydro, Alcoa, Bellona Europe and Sandbag was published by Carbon Pulse. The EU’s Carbon Border Adjustment Mechanism (CBAM) was established to extend Europe’s carbon...
Supply and demand in the EU ETS: It’s the hydrogen, stupid!
This note analyses the supply and demand balance of the EU ETS until 2030. It is based on Sandbag’s ETS Simulator, which was updated with the market’s latest data and policy parameters. • The...
Key dates in the calendar (in progress)
In bold: legislative date
2024 – Emissions from maritime transport are covered in EU ETS for cargo and passenger ship over 5,000 gross tonnage (40% of the emission are covered in 2024, 70% in 2025, and in 2026 it will be 100% for ship travelling within the EU and 50% for ships travelling between EU and non-EU ports)
2024 – Installations for the incineration of municipal waste above a certain threshold are required to monitor and report their emissions in the EU ETS
By 30 June 2024 – Implementing Regulation laying down the detailed rules for calculating CORSIA-related offsetting under Article 12(7) of EU ETS Directive
18 June 2024 – Public consultation until 16 July & publication of draft Delegated Act on the inclusion of permanent CCU in the EU ETS
11 July 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)
By 31 August 2024 – Implementing Regulation laying down the detailed rules for monitoring and reporting the non-CO2-effects of aviation (Article 14(5) of EU ETS Directive)
September – October 2024 : Open public consultation of the revision of the Activity Level Change regulation
September 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)
November 2024 – Vote in CCC on the revision of the Activity Level Change Regulation
December 2024 – Envisaged adoption of the revision of the Activity Level Change Regulation
2024 – Inclusion of methane and nitrous oxide emissions in the monitoring, reporting and verification of emissions from maritime transport
By the end of 2024 – Adoption of a Delegated Act on a support mechanism for the use of eligible fuels, which will distribute emission allowances to cover the price difference to kerosene
By the end of 2024 – Delegated Act amending the ETS Monitoring & Reporting Regulation to include requirements for reporting the use of CORSIA eligible fuels and unit cancellation
2025 – Beginning of the monitoring and reporting of emissions covered under ETS2
Q1 2025 – Delegated Act on Free Allocation Rules in force
Q1 2025 – Revision of the Activity Level Change Regulation in force
By 1 January 2025 – Regulated entities covered by the ETS2 are required to hold a greenhouse gas emissions permit and an approved plan for monitoring their annual emissions
June 2025 – Social Climate Plans to be submitted by Member States to the European Commission
2026 – Full auctioning of emission allowances to aviation
2026 – Social Climate Fund enters into force
By 2026 – Analysis on the feasibility of including municipal waste incineration installations in the EU ETS from 2028
By early 2026 – The EC creates an EU-wide investment atlas of potential CO2 storage sites
2026 – Inclusion of methane and nitrous oxide emissions from maritime transport in the EU ETS
By 21 December 2026 – Report by the EC on the feasibility and economic, environmental and social impact of the inclusion of ship between 400 and 5,000 gross tonnage
2027 – ETS2 becomes fully operational (postponed to 2028 in case of exceptionally high gas or oil prices in 2026)
2039 – The EU ETS cap reaches zero
In bold: legislative date
1 July 2024 – CBAM rules on the verification of embedded emissions; maximum use of default values (when reporting embedded emissions) goes down from 100% to 20%
31 July 2024 – Deadline to finalise 2023 CBAM declarations
Q3 2024 -Implementing Act :
- Authorisation of CBAM declarants (two separate acts)
- Technical arrangements of CBAM Registry
Q4 2024 and Q5 2025 – Implementing Act and Delegated Act: accreditation of verifiers (IA+DA) & verification principles (IA)
Q4 2024 – Delegated act : sale and re-purchase of CBAM certificates
Q4 2024 – Implementing Act :
- Goods brought to the continental shelf or the exclusive economic zone
- Communication and information of imported goods at the border
Q4 2024 -Report by the EC on recommendations for the inclusion of other relevant downstream products of the goods listed in Annex I, including a methodology
Q1 2025 : Final deliverable of studies by the Commission on:
- Finalisation of default values
- Rules for monitoring, reporting and verification (MRV) of embedded emissions during the definitive period & adjustment for free allocation
- Adjustment for carbon price paid abroad
28 February 2025 – Deadline to finalise 2024 CBAM declarations
Q2 2025 – Implementing Act
- CBAM Declaration
- Calculation of embedded emissions
- Carbon price paid in third countries
- Price of CBAM certificates
- Adjustment for free allocation
Q2 2025 : Final deliverable of studies by the Commission on:
- Scope extension to indirect emissions
- Scope extension upstream and for new goods and transport services
- Scope extension to downstream goods
Q4 2025 & Q3 2028- Report by the EC on an assessment of the reports submitted by third countries on the fulfilment of conditions to be exempted from CBAM for electricity as a CBAM good
Q4 2025 – Report on the application of CBAM, including on possibility to extend the scope
Q4 2025 and every year thereafter – Report on impact on LDC’s (decarbonisation of manufacturing industries)
31 December 2025: the CBAM is implemented as a transitional measure, with obligations limited to monitoring and reporting
1 January 2026 – start of the definitive period, CBAM implementation :
- the Commission is empowered to modify the list of goods subject to the CBAM for anti-circumvention purposes
- Importers will need to declare each year the quantity of goods imported into the EU in the preceding year and their embedded GHG. They will then pay for it with the corresponding number of CBAM certificates
28 February 2026 – Deadline to finalise 2025 CBAM declarations
Q3 2027 – Report by the EC on the delegation of power to adopt delegated acts
Q4 2027 and every two years thereafter – Reports by the EC on CBAM functioning, its impacts (internal market, consumer prices, industries, trade) and possible adjustments in application (scope, governance)
Q4 2027 and every two years thereafter – Report by the EC on impact on exports
In bold: legislative date
June 2024 – Entry into force of the Gas Package
2024 – Creation of the European Network of Network Operators for Hydrogen (ENNOH)
Between 2024 and 2026 – ENNOH and European Network of Transmission System Operators for Gas (ENTSOG) will work together
December 2024 – Delegated Act on the definition of the methodology for the certification of low carbon gas
End of 2024 – Second auction of the European Hydrogen Bank
End of 2024 – At least 6 GW of renewable hydrogen electrolysers are supposed to have been installed in the EU
2025 – Report by the EC on the production, transport and uptake of renewable hydrogen in industry and transport.
June 2025 – Agency for the Cooperation of Energy Regulators (ACER) recommendations on inter-temporal cost allocation for Transmission System Operators (TSOs) and Distribution System Operator (DSO)
June 2026 – Member States to ensure that hydrogen TSOs are unbundled in accordance with the rule for gas TSOs
June 2026 – Maximum timeline for transposition of the Gas Package directive by Member States
1 January 2027 – European transmission network operator for hydrogen (ENNOH) to be fully operational and independent
2028 – Update by Member States of their Network Decommissioning Plans (NDPs) for their unused gas networks.
By 31 December 2030 – Review by the EC on the methodology for low carbon gases
2034 – ACER’s report on the impact of the unbundling rules for hydrogen DSO and TSOs
2025 – Communication by the EC on the implementation of unbundling rules for hydrogen TSOs and DSOs
By 31 December 2030 – Assessment of whether facilities that begin operation from 1 January 2031 should demonstrate huger greenhouse gas emission saving
1 January 2033 – End of the fixed tariff for hydrogen at interconnection point, each national regulator will now fix their own tariffs
2030 – At least 40 GW of renewable hydrogen electrolysers are supposed to have be installed in the EU
June 2024 – Public consultation until 16 July & publication of draft Delegated Act on the inclusion of permanent CCU in the EU ETS
By 2025 : The European Commission develops a step by step guidance for permitting processes for net-zero strategic projects for CO2 storage
By early 2026 :
- The EC creates an EU-wide investment atlas of potential CO2 storage sites
- A platform for demand assessment ad demand aggregation for C02 transport or storage services
- The EC assesses with the EU ETS 2026 review if and how the CO2 removed from the atmosphere and safely and permanently stored could be accounted for and covered by emissions trading
2027 – The EU Innovation Fund, which supports carbon capture and storage projects, becomes operational
2030 – By this year, the EU plans to have available capacity to annually store 50 million tonnes of CO2
In bold: legislative date
9 July 2024 – Online workshop for peatland by DG Clima (European Commission)
September 2024 – Online workshop on agriculture and forestry, and another one on bio-based building by DG Clima (European Commission)
September 2024 – Stakeholders workshop on rules for verification and registries by DG Clima (European Commission)
September 2024 – Draft methodologies for BECCS and DACSS, Strawman methodology biochar
October 2024 – Fifth Expert Group meeting on the CRCF regulation
2024 and 2025 – Workshops on novel removals and financing options for removals by DG Clima (European Commission)
2025 – Delegated acts for firsts certification methodologies and implementing acts for verification and registry rules
April 2025 – Draft methodology for biochar carbon removals by the EC
2026 – First biochar units to be certified by the EC
By 31 July 2026 – EC report on how and if carbon removals could be accounted for and integrated into the EU ETS
2028 – CRCF certification methodologies finalised
In bold: legislative dates
2024 – Decrease of 25% in free allocation to the aviation sector
By 30 June 2024 – Implementing Regulation : Detailed rules for calculating CORSIA-related offsetting under Article 12(7) of EU ETS Directive
By 31 August 2024 – Implementing Regulation : Detailed rules for monitoring and reporting the non-CO2-effects of aviation (Article 14(5) of EU ETS Directive)
By the end of 2024 – Delegated Act : Support mechanism for the use of eligible fuels, which will distribute emission allowances to cover the price difference to kerosene
By the end of 2024 – Delegated Act : amending the ETS Monitoring & Reporting Regulation to include requirements for reporting the use of CORSIA eligible fuels and unit cancellation
2025: Implementing decision on the list of credits eligible for CORSIA offsetting under the ETS Directive (Article 11a(8))
March 2025 – First reporting by airlines of their fuel use (covering 2024)
2025 – Monitoring and reporting by aircraft operators of non-CO2 effects
2025 – Decrease of 50% of free allocation to the aviation sector
2026 – European Commission to publish results on non-CO2 effects of air transport
2026 – European Commission to carry out an assessment of CORSIA to see if it’s sufficiently delivering on the goals of the Paris Agreement.
2026 – Full auctioning of emission allowances to aviation (phase-out of free allowances to the aviation sector)
2027 – EU carbon pricing may start to apply to international flights, depending on the conclusion of the assessment of CORSIA’s efficiency to meet the goals of the Paris Agreement
In bold: legislative dates
11 June 2024 – Stakeholder Consultation on the 2024 Innovation Fund Calls for Proposals
12 June 2024 – Stakeholder Consultation on the draft Terms and Conditions for the second renewable hydrogen auction
27 June 2024 – Innovation Fund Expert Group meeting
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