Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

Stegra fully supports the objective of CBAM and recognizes that it, together with the phase-out of free allocation in EU ETS, is one of the most important prerequisites to decarbonize the industry in EU while also incentivizing decarbonization outside EU. The EU ETS and benchmarks for free allocation are based on processes, whereas the CBAM is based on goods. Simultaneously, the same type of good (e.g.

The CBAM product benchmarks shall be defined by using a similar methodology than the one used for determining the EU ETS product benchmarks. The benchmark scope shall take into account process emissions, direct emissions linked to energy consumption and indirect emissions linked to purchased heat.

Aluminium France is concerned about the risks of circumvention linked to the current design of CBAM. Therefore, for direct emissions, we call for a single default value based on the average carbon footprint of the fusion country.

Filed in French · English published by the European Commission

Notat 25. september 2025 J.nr. 2025 - 6366 Kontor: International Skattepolitik [ISK] Initialer: Danish response to the European Commission’s call for evidence The Danish relevant authorities’ thanks for the possibility to reply to the Commission’s call for evidence for views on the Commission’s understanding of the problem and possible solution which is likely three Commission Implementing Regulations laying down…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposed approach using CBAM benchmarks is surprisingly complex. A different approach (which we had assumed as the obvious solution) would consist of simply mirroring the EU ETS. In the ETS, there is no such thing as a steel benchmark, so the allowances given for the production of steel are dispatched between individual process.

This document presents the comments of the Brazilian Aluminium Association (ABAL) on the European Commissions Public Consultation for Preparing an Implementing Regulation on how the Carbon Border Adjustment Mechanism (CBAM) certificates to be surrendered by authorized CBAM declarants must be adjusted to reflect the extent to which EU Emissions Trading System (ETS) allowances are allocated free of charge.

CBAM does not provide the same carbon leakage protection granted by the current level of ETS free allowances and a broad eligibility for indirect carbon costs compensation. The current CBAM framework does not sufficiently prevent industries to relocate outside Europe, and therefore it is not enough to ensure EUs industry competitiveness and progress towards climate transition.

The Würth Group supports the Commission’s objective to ensure equal treatment of goods produced in the EU and in third countries by adapting the CBAM obligations. Of particular importance is the consideration of free allocation of EU ETS allowances, which will be phased out by 2034. Our procurement concerns mainly DIN and standard parts, which are mostly manufactured outside the EU.

Filed in German · English published by the European Commission

Maintain parity with the EU ETS by applying a transparent, published formula that aligns CBAM obligations with the share of EU free allocation. For consistency, the European Commission is requested to provide replicable worked examples for iron and steel and clear rules for annual updates to benchmarks and free-allocation shares.

In the context of the call for feedback on the implementing act under the Carbon Border Adjustment Mechanism (CBAM), the European Tyre Industry (ETRMA) would like to share its key recommendations. Tyre manufacturing is energy intensive. It enables Europes economy and society. Without tyres, Europeans cannot move, our economy grinds to a halt, and our defence and agriculture are unable to function.

CBAM Benchmarks (ETS references) CBAM Benchmarks should reflect the best environmental practices and reducing the risk of circumvention. UNESID welcomes the Commissions consultation on CBAM benchmarks. We agree that benchmarks must reflect the principles of the ETS, ensuring both environmental integrity and a fair level playing field. However, several points deserve stronger emphasis: 1.

Highlights: Transparency whereas the final phase will start in 2026, it is requested that details on how free EU ETS allowances will be reflected in the CBAM be published as soon as possible. We also reinforce the need for the Commission to establish a clear timeline for the publication of this Implementing Regulation.

Filed in Portuguese · English published by the European Commission

Specifically on the methodology, the CBAM product benchmarks shall be defined by using a similar methodology to the one used for determining the EU ETS product benchmarks. The benchmark scope shall take into account process emissions, direct emissions linked to energy consumption and, where relevant, indirect emissions linked to purchased heat.

The voice of Polish business and scientific community in Brussels Brussels, September 2025 Commission Implementing Regulations laying down detailed rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council establishing a carbon border adjustment mechanism Business & Science Poland position In Regulation (EU) 2023/956 establishing the Carbon Border Adjustment Mechanism…

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for the opportunity to express our opinion on the CBAM. It is evident that the treatment of CBAM certificates submitted by certified declarants must be adjusted to reflect the scope of free allocation of EU Emissions Trading Scheme (ETS) allowances. We recognize that how such adjustments are made is primarily an internal EU matter and not one on which companies in third countries should take a position.

CBAM IMPLEMENTATION: RULES ON THE METHODOLOGY FOR CALCULATING EMBEDDED EMISSIONS, THE ADJUSTMENT OF CBAM CERTIFICATES & THE CARBON PRICE PAID IN A THIRD COUNTRY EUROPEAN ALUMINIUM RESPONSE TO THE CALLS FOR EVIDENCE Brussels, September 2025 Background We fully support the EU’s climate objectives and the prevention of carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

September 2025 Call for evidence - CBAM adjustment of obligation to surrender them to take account of free ETS allowances Air Liquide welcomes the introduction of CBAM as a tool to address carbon leakage risks, and to foster decarbonisation in the EU and abroad.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to the European Commission Call for Evidence on CBAM certificates - adjustment of obligation to surrender them to take account of free ETS allowances. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

The Industrial Gas (IG) sector is strongly integrated into the value chains of industries it serves, such as steelmaking, chemical manufacturing and oil refining. In mature economies, IG consumers may decide either to self- produce (i.e. insourcing business model) or to outsource their IG needs to IG producers (i.e. outsourcing business model). Outsourcing to a company like an EIGA member has significant benefits.

Cemminerals NV is a strong believer of a fair and equal playing field for importers and producers with the gradual phasing-out of the ETS free allowance system and creation of CBAM. We hereby confirm our position in this area in order to reduce the carbon impact of the cement sector and participation in the European Green Deal strategy.

With the CBAM set to come into force in its final form in January, we share concerns about the lack of visibility and delays in defining key elements of this regulation. For some of our multinational subsidiaries in the construction sector, the implementation of the CBAM is a factor to be taken into account for certain large projects, particularly when these projects span several years and require a multi-year cost…

Brussels, September 2025 Fertilizers Europe Position on EU Commission Call for Evidence on CBAM methodology Fertilizers Europe represents the majority of fertilizer producers in the European Union. As a key player in the food value chain, the European fertilizer industry is crucial to ensure food security and strategic autonomy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROFER paper: CBAM benchmarks should reflect best environmental practises The CBAM benchmarks are meant to reflect the level of free allocation granted to European industry in order to ensure an effective carbon leakage protection and a level playing field with importers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MPE represents the European producers of rigid metal packaging, a sector that relies heavily on competitively priced steel and aluminium. We share the EUs climate neutrality objectives and recognise the Carbon Border Adjustment Mechanism (CBAM) as a key tool to reduce carbon leakage.

We welcome the opportunity to provide feedback on the different calls for evidence on the Carbon Border Adjustment Mechanism (CBAM). We strongly support a timely, effective and full implementation of the EU CBAM in 2026. In a challenging international context, regulatory stability and predictability are quintessential for a competitive and clean European industrial basis.

O'Brien Cement thanks the European Commission for the opportunity to respond to the call for evidence on the CBAM Implementation Regulation to establish the methodology for the final period of the mechanism, starting on 1 January 2026. OBrien Cement is a family-owned independent cement manufacturer operating from Port of Waterford, Ireland since 1978.

The current methodology for calculating embedded carbon under the EU Emissions Trading System (ETS) and the Carbon Border Adjustment Mechanism (CBAM) does not adequately recognise the environmental benefits of waste-derived fuels compared to fossil fuels.

RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 31 of the CBAM Regulation. Clear rules on the free allocation adjustment are essential to safeguard competitiveness and maintain the credibility of CBAM.

Member of European Chemical Industry Council CEFIC Warsaw, 24.09.2025 PIPC/108/2025 PIPC Submission – CBAM Implementing act on adjustment for free allocation As the national organization representing the chemical industry in Poland, the Polish Chamber of Chemical Industry (PIPC) is pleased to provide input on the proposed implementing act concerning the adjustment of CBAM certificates to reflect free allocation…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Free Allocations to the cement sector in the EU ETS are from January 2026 based on the binder benchmark, covering both clinker and 4 alternative hydraulic binders. For the period 2026 2034, the free allocations are reduced by the CBAM reduction factor and the Cross Sectoral Correction factor. The EU ETS allocations and benchmark are per 1 January 2026 based on the binder benchmark.

Statement of the Korea Iron and Steel Association (KOSA) regarding the implementation of the European Carbon Border Adjustment Mechanism(CBAM) 25 September, 2025 Korea Iron and Steel Association (KOSA) 15F, IT Venture Tower (East Wing), 135 Jungdae-ro, Songpa-gu, (78 Garak-dong), Seoul, 05717, Republic of Korea [phone removed] / [email removed], [email removed] I. Introduction 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cem'In'Eu thanks the European Commission for the opportunity to respond to the call for evidence on the CBAM Implementation Regulation to establish the methodology for the final period of the mechanism, starting on 1 January 2026.

The International Emissions Trading Association (IETA) welcomes the opportunity to provide input on the Commissions Call for Evidence regarding the adjustment of CBAM obligations to account for the free allocation of EU ETS allowances.

Eren Holding is a company with long-standing trade relations with the European Union and a regular exporter to the EU market, in particular in the cement sector. The Carbon Border Adjustment Mechanism (CBAM), adopted under the European Green Deal, has direct implications for our operations and trade with the EU.

Lithuanian Business Confederation (LVK) submits its position to the ongoing European Commission consultations on the Carbon Border Adjustment Mechanism (CBAM). The document outlines key challenges for businesses, emphasizes the need for proportional and carefully assessed implementation, and proposes measures to safeguard EU industry competitiveness while supporting decarbonisation efforts.

Methodology for calculating embedded free allocation: We support the development of product benchmarks, fallback and process emissions benchmark for each relevant production process based on current EU ETS facility benchmarks. This will ensure a fair comparison between external producers and European producers.

CMC Poland supports The Polish Steel Association and EUROFERs position on CBAM benchmarks and welcomes the Commissions efforts to ensure a fair and climate-effective implementation. CBAM benchmarks should reflect the best available environmental practices, consistent with the objective of reducing global emissions and ensuring a level playing field with third countries.

Bellona strongly supports the phase-out of EU ETS free allowances in line with the introduction of CBAM. The timeline and rate of the phase-out must remain consistent, without changes or extensions. Free allowances were introduced as a temporary measure to mitigate carbon leakage risks and have persisted for nearly two decades, undermining the long-term signal for emissions reductions and delaying industrial…

BMW welcomes the opportunity to contribute to the ongoing EU consultations regarding the CBAM: methodology for the definitive period; carbon price paid in a third country; adjustment of obligation to surrender them to take account of free ETS allowances.

A few months after the CBAM entered into force, the situation is still marked by a lack of regulatory and operational clarity, which creates serious legal uncertainty, prevents companies from planning rigorously in 2026 and threatens to distort competition on the European market.

Filed in Spanish · English published by the European Commission

With the full implementation of the CBAM scheduled for 1 January 2026, major concerns remain unresolved. The regulatory framework is unfinished, operational procedures are undefined, and importers still lack the essential information needed to comply.

Feedback on CBAM Consultation: Adjustment of Obligation to Surrender Certificates to Reflect Free ETS Allowances We welcome the opportunity to provide feedback on the adjustment of CBAM surrender obligations to take account of free allowances under the EU Emissions Trading System (EU ETS). The following points highlight key concerns and recommendations: 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find below Eurometaux's key messages and attached our position paper on the free allocation adjustment. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals.

The German Cement Works Association (VDZ) fully supports the Carbon Border Adjustment Mechanism (CBAM) as a cornerstone of EU climate and industrial policy and prerequisite for deployment of climate-neutral technologies.

Warsaw, 25th September 2025 ORLEN position on the projected: methodology for calculating emissions embedded in cbam goods; rules on the adjustment of cbam certificates to reflect the eu ets free allocation; rules on the deduction of the carbon price paid in a third country 1. ORLEN GROUP:  ORLEN Group is an integrated, multi-utility corporation primarily active in Central Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the first ultra-clean steelmaking facility in Spain, Hydnum Steel strongly supports the CBAM and welcomes the European Commissions efforts to drive global decarbonization in steel and other essential sectors. Please find attached our contribution to the public consultation on the CBAM. We hope it supports the ongoing work, and we remain available for any further clarification or dialogue.

UNFAIR POSITION OF EU IMPORTERS IN RESPECT OF EMISSIONS PRICE We would like to point out to the Commission that in 2026, EU importers will be in a worse position than EU producers included withing the scope of EU ETS (hereinafter referred to as EU ETS producers).

CBAM design is not suitable to be extended to the complex value chains such as those of organic chemicals and polymers. Four key conditions a solution for exports, full value chain coverage, consideration of indirect carbon costs, and practical feasibilityremain unmet.

Thank you for your consultation on these CBAM topics. With the "Commission proposal to simplify and strengthen the CBAM", the Commission wants to simplify the CBAM and align it with the EU ETS. Bringing the actual regulation to an operationally stable state should be achieved before December 2025 to avoid any issues for the millions of manufacturing companies using and disrupting the EU supply chains.

SEPTEMBER 2025 Glass Alliance Europe’s input to the call for evidence on Carbon Border Adjustment Mechanism Glass sectors - including container glass, flat glass, special glass, domestic glass, continuous filament glass fibres, and mineral glass and stone wool insulation - are covered by the EU Emissions Trading System (EU ETS) and recognised as being at significant risk of carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Danish Industry advocate for a balanced and workable CBAM, that effectively prevents carbon leakage and protects competitiveness of European industries, while simultaneously recognizing the impact on downstream supply chains.

We urge the European Commission to hold further public consultations on the draft implementing rules concerning the methodology for calculating emissions embedded in CBAM goods, the adjustment of CBAM certificates to reflect the EU ETS free allowances, and the rules on the deduction of the carbon price paid in a third country. This is essential to ensure transparency and uphold the rights of all stakeholders.

Call for Evidence CBAM certificates – Adjustment of obligation to surrender them to take account of free ETS allowances Implementing Act on Free Allocation 24 September 2025 Background The European Fertiliser Blenders Association (EFBA) represents national associations in several EU Member States, the United Kingdom and Switzerland whose member businesses are involved in the production of compound blended…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Business for CBAM Coalition Position on rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation The European Commission is consulting on an implementing regulation that will establish detailed rules on how free allocation of Emissions Trading System (EU ETS) allowances between 2026 and 2034 should be reflected in the obligations under the Carbon Border Adjustment Mechanism (CBAM).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The current method has a high degree of freedom in the calculation system, which is why it is complex in determining the volume of CBAM certificates to be purchased. Determining punctual benchmarks for each stage of the production process is practically a long way to standardise the calculation of CBAM and put all values on equal footing.

Filed in Italian · English published by the European Commission

The implementation of the consideration of free allocation of CO2 allowances for CBAM shall be simple and comprehensible. How will free ETS certificates and CBAM certificates be taken into account in the future calculation? It is unclear whether and how free allowances (from ETS) can be taken into account in CBAM. There is no concrete legislative proposal for implementation.

Filed in German · English published by the European Commission

25. September 2025 Stellungnahme des Zentralverbands Oberflächentechnik e. V. (ZVO) zur CBAM-Umsetzung (Durchführungsverordnungen nach Art. 7, 9 und 31 der VO (EU) 2023/956) 1. Kurzfazit Der ZVO unterstützt das Ziel, Carbon Leakage zu verhindern und gleiche CO₂-Kosten für importierte und in der EU hergestellte Waren sicherzustellen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Article 31(2) requires CBAM adjustments to mirror ETS allocation rules and to decline linearly with the ETS phase-out (20262034). Key principle: Transparency: Article 30(6) requires monitoring and reporting; benchmarks and datasets must be public and regularly revised.

Adjusting CBAM Certificates to Reflect Free Allocation: Feedback from Federation of Thai Industries (FTI) The Federation of Thai Industries (FTI), representing Thai manufacturers, wishes to convey our principal concerns regarding the application of the Carbon Border Adjustment Mechanism (CBAM) to Thailand.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir/Madam, As a cold rolling mill based in Türkiye and exporting to the European Union, we welcome the opportunity to provide feedback on the implementation of the Carbon Border Adjustment Mechanism (CBAM). While we fully support the EUs climate objectives, it is essential that CBAM reflects actual industrial practices and ensures fair competition. Our key considerations are attached.

The CBAM benchmarks are meant to reflect the level of free allocation granted to European industry in order to ensure an effective carbon leakage protection and a level playing field with importers. Therefore, they play a major role in the calculation of the CBAM obligation, since they are discounted from the total costs of embedded emissions.

Emirates Global Aluminium (EGA) welcomes the opportunity to contribute to the European Commissions Call for Evidence on CBAM. As a material supplier of primary aluminium to the EU, EGA supports CBAMs goal of ensuring a level playing field between EU and non-EU producers in respect to the costing of emissions and aligning trade policy with climate objectives. Please see attached our comments.

We stress that the treatment of free allocations under the EU Emissions Trading System (ETS) for CBAM allowances must be fair, transparent and not distortive. Therefore, we strongly recommend that the rules avoid a double burden on carbon costs and provide for a sector-specific methodology to ensure a level playing field. At the same time, there is great concern about the lack of benchmarks for CBAM as of 2026.

Filed in German · English published by the European Commission

This submission presents the comments of the Hyundai Steel Company, established in the Republic of Korea (South Korea), Hyundai Steel Slovakia s.r.o. and Hyundai Steel Czech Republic s.r.o., (collectively referred to as the Hyundai Steel Group or "HSG").

Ref. September Ares(2025)8055416 2025 - 25/09/2025 POSCO's Comments in Response to the European Commission’s Call for Evidence on the Implementation of CBAM Executive Summary POSCO fully supports the environmental objectives of the Carbon Border Adjustment Mechanism (CBAM) and welcomes the European Commission’s efforts to simplify the mechanism, enhance legal certainty, and promote the use of actual emissions data.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The interaction between CBAM certificates and the phase-out of free allowances under the EU ETS must be designed with clarity and precision to avoid market distortions and administrative complexity. The Commission should clarify whether adjustments for free allowances will be applied at the level of aggregated product groups or at the level of individual CN-code commodities, since this choice will determine the…

1.Difficulties in Correlative Conversion Caused by the Difference Between CBAM Certificate Costs and Costs for EU Steel Enterprises to Participate in the Carbon Market The Carbon Border Adjustment Mechanism (CBAM) requires the reporting of commodity combinations and carbon emission information based on integrated commodity categories.

1. Implementing act on free allocation • • • • Benchmarking Methodology: The plan to derive CBAM benchmarks from EU ETS benchmarks is a specific point of concern. EU benchmarks are based on the performance of the top 10% of EU installations, which often use advanced, low-carbon technologies. For many developing countries, these benchmarks are not a realistic or achievable target.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Viet Nam requested that the competent authority, based on ISO 14067, include by-products of the steelmaking process (such as granulated blast furnace slag, steel slag, sulfur, etc.) in carbon emission allocation, or establish a mechanism allowing steel industry by-products to be deducted from the sectors carbon emissions.

Emerson’s response to the call for evidence (1) on the Carbon border adjustment mechanism (CBAM) methodology for the definitive period starting on 1 January 2026, and (2) CBAM certificates – adjustment of obligation to surrender them to take account of free ETS allowances. Introduction.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Europacable welcomes the opportunity to respond to the call for evidence on the CBAM adjustment of obligation to surrender CBAM certificates to take account of free ETS allowances. A study commissioned by Europacable in 2023 confirmed that aluminium power cables are a key technology to empower Europes decarbonisation.

As a European manufacturing company primarily engaged in the production and export of mining machinery and components to markets outside the European Union, we respectfully submit the following concern regarding the current scope of the Carbon Border Adjustment Mechanism (CBAM). Many of the goods we export may include components originally imported into the EU and covered under CBAM.

The gradual phase-out of free allowances under the EU ETS system, scheduled between 2026 and 2034, represents a crucial transition that coincides with the full entry into force of the CBAM. The implementing act under Article 31 of Regulation (EU) 2023/956 must clearly define how free allocation will be translated into a discount on CBAM certificates, ensuring equal treatment between goods produced in the EU and…

Adjustment for the free allocation under the EU ETS: The adjustment mechanism for CBAM obligations shall take into account the free allocation of emission allowances to Union industries under the EU ETS, which is to be phased out gradually over the period 20262034, pursuant to Article 31 of Regulation (EU) 2023/956.

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of the CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start in 2026.

(1)To ensure competitive fairness with European producers, the certificate calculation mechanisms must be clear and efficient, ensuring that nitrogen fertilizer producers outside the EU are treated equivalently to EU producers. This must consider the free allowances granted to European producers so that exporters outside the EU do not bear a disproportionate burden compared to their European competitors.

Executive summary: WE Soda urges the EU Commission to expand the Carbon Border Adjustment Mechanism (CBAM) to include the soda ash and glass industries in line with the EU policy objectives. WE Sodal also calls for an integrated assessment and design of CBAM benchmarks to ensure that low-carbon soda ash has a level playing field with high-carbon soda ash produced in Europe.

o It is essential that CBAM benchmark values get published at the earliest opportunity, so that cost impacts can be assessed and planned accordingly. o The benchmark values should accurately reflect the average emission levels within EU ETS, to keep a level playing field with ETS and not create distortions.

CBAM must ensure genuine alignment with ETS free allocation to secure a level playing field. Exporters require transparent, predictable, product-level benchmarks and tools to estimate certificate obligations in advance. The adjustment schedule should follow a linear, synchronized path with ETSs phase-out of free allocation, providing long-term certainty.

Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the opportunity to respond to the CBAM Call for Evidence and welcome the EUs efforts to address carbon leakage.

The 2 elements for calculating the CBAM price and understanding the impact it will have on an organisation have not yet been published 3 months after the start of the mandatory reporting period, i.e. the ‘CBAM benchmarks’ and the carbon price. Without this information, the prior calculation of the costs to be incurred by importers is at least impossible.

Filed in Italian · English published by the European Commission

EUROMETAL supports CBAM as a cornerstone of EU climate and trade policy. Its success depends on the clarity and stability of rules, the adoption of workable methodologies adapted to SMEs in steel distribution, fair recognition of carbon prices paid abroad, proportionate and harmonised reporting obligations, and closing the loophole by extending CBAM coverage to steel derivatives.

We, the Japan Iron and Steel federation, propose the following for the effective implementation of CBAM: (1) adopt the bubble approach, as applied during Phase 1, to reduce excessive administrative and compliance burdens; (2) if default values must be used, allow governments which maintain mutual trust relationships with the EU (e.g., through EPAs), with statutory reporting systems to provide reliable national…

Attached is the Ministry of Economic Affairs, Republic of China (Taiwan), paper outlining our comments and recommendations on this consultation. 1.Run a public consultation after publishing drafts on (i) adjusting CBAM certificates to reflect EU ETS free allocation and (ii) CBAM benchmarks, to build consensus, ensure transparency, and protect stakeholder interests.

EUROFER paper: CBAM benchmarks should reflect best environmental practises The CBAM benchmarks are meant to reflect the level of free allocation granted to European industry in order to ensure an effective carbon leakage protection and a level playing field with importers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GravitHy welcome the Commissions initiative to clarify the implementation rules of the CBAM. For first-of-a-kind industrial projects such as ours, regulatory clarity and predictability are essential to unlock investment and ensure that Europes decarbonization objectives translate into industrial reality.

Subject: Commentary on the European Commission's Call for Evidence for the Carbon Border Adjustment Mechanism (CBAM) Implementing Acts on Adjustment for Free Allocation of EU ETS (Article 31) The Thailand Greenhouse Gas Management Organization (Public Organization) (TGO) would like to extend its warm appreciation to the European Commission for initiating the official consultation on the implementing acts for the…

The Polish Steel Association supports EUROFERs position on CBAM benchmarks and welcomes the Commissions efforts to ensure a fair and climate-effective implementation. CBAM benchmarks should reflect the best available environmental practices, consistent with the objective of reducing global emissions and ensuring a level playing field with third countries.

Although not currently in the inclusive sector in the studies in the CBAM field, considering that our sector will be included in the short or medium term due to the involvement of our stakeholders in the relevant mechanism, implementation oversight and compliance mechanisms should be more clearly defined.

This initiative outlines detailed rules governing the adjustment of CBAM certificates to be surrendered by authorised CBAM declarants, in order to reflect the extent to which allowances under the EU Emissions Trading System (EU ETS) are allocated free of charge. These rules should be aligned with the principles of the EU ETS, taking into consideration the various EU ETS benchmarks used for free allocation.

As IVSH we welcome the Commissions initiative regarding CBAM certificates and adjustements. However, we would like to emphasize once again a key point from our previous input on the downstream extension: For CBAM to achieve its climate and competitiveness objectives, it is essential to fully include downstream goods such as cookware, cutlery, and other metal-intensive household products.

CELSA Group, as one of Europes leading steel producers, welcomes the opportunity to contribute to the consultation on the CBAM certificates - adjustment of obligation to surrender them to take account of free ETS allowances.

Feedback to the European Commission CBAM Implementing Acts 1. Distortion of competition due to CN 7314 As EU producers of gabions, we use galvanized steel wire (CN 7217) as our main input. Wire is covered by CBAM. From 2026 we will be required to surrender CBAM certificates for the embedded emissions of the imported wire and bear the associated cost.

How will the payment for indirect emissions be determined for the cement sector, considering that no new benchmark values have been published for the 2026-2030 period, and that benchmark values for cement as a CBAM product are still lacking? With the start of the definitive period fast approaching, it remains impossible to accurately estimate the costs associated with exports in 2026.

Gerber Steel GmbH respectfully submits its position on the initiative CBAM certificates - adjustment of obligation to surrender them to take account of free ETS allowances. The attached statement details our concerns on the interaction between CBAM and ETS benchmarks as well as our recommendations for a fair and non-discriminatory methodology. We are, of course, available at any time for queries and consultations.

Good day, to date, there is still no clear information on real Benchmark, the cost of CBAM certificates, which means that entrepreneurs cannot financially plan investments, strategic choices, and this is nothing more than the mirror of those who govern us, that is to say, not having fallen into reality.

Filed in Italian · English published by the European Commission

This initiative sets out a set of detailed rules on how the certificates of the CO2 Border Adjustment Mechanism (CBAM) that authorised CBAM declarants are required to surrender should be adjusted to reflect the size of the EU Emissions Trading System (EU ETS) allowances allocated free of charge.

Filed in Italian · English published by the European Commission

CBAM benchmarks should reflect best environmental practices. The CBAM benchmarks are meant to reflect the level of free allocation granted to European industry in order to ensure an effective carbon leakage protection and a level playing field with importers. Therefore, they play a major role in the calculation of the CBAM obligation, since they are discounted from the total costs of embedded emissions.

According to ASSOFERMET, CBAM declarants will only have to surrender annually a percentage of CBAM certificates, determined in proportion to the free allocation of ETS allowances for the same goods. The total number of certificates to be purchased and returned to the EU Commission must therefore be correctly linked to the emission allowance recognised free of charge under Article 10 (a) of Directive 2003/87/EC.

Filed in Italian · English published by the European Commission

As power trader, Danske Commodities A/S, based in Denmark, have several borders where we flow/import electricity towards EU. The CBAM regulation in it's current state will affect cross-border trading negatively as it will impose tariffs and administration burdens to these operations.

Norsk Hydro advocates for strengthening CBAMs methodology to mirror the EU ETS by closing loopholes, assigning emissions to scrap, keeping indirect emissions out of scope for aluminium, and ensuring electricity rules remain enforceable and realistic, with the core principle that imported CBAM goods should face the same carbon costs as if produced in Europe, without incentives to circumvent the system.

FuelsEurope welcomes the European Commissions consultation of stakeholders on the Implementing Regulation on the adjustment of obligation to surrender CBAM certificates to take account of free ETS allowances. FuelsEurope believes that, considering the complexity of Free Allocation Rules, most of the complexity should be managed by the Commission or by the Member States and customs authorities , and not by…

The allocation of ETS free allowances from January 2026 is based on a benchmark for grey cement binders, which includes both cement clinker and alternative hydraulic binders. This benchmark will be determined on the basis of data collection from European Emissions Trading Systems. For the period 2026-2034, free allocation shall be gradually reduced by a CBAM factor and by a possible correction factor.

Filed in German · English published by the European Commission

In the context of the implementation of the Carbon Border Adjustment Mechanism (CBAM), the direct relationship with the European Emissions Trading System (EU ETS) should be taken into account, particularly with regard to the free allocation granted to facilities within the EU. These criteria can be combined as follows: 1.

Coilinter Internationaler Stahlservice GmbH & Co. KG Flachsbleiche 14 D-41564 Kaarst Sehr geehrte Damen und Herren, zur Sondierung - Ares(2025)6962930 möchten wir hinsichtlich der Preisfindung /Preisentstehung der CBAM-Zertifikate Stellung nehmen: 1. Es ist vorgesehen, dass sich der Preis für CBAM-Zertifikate am Preis der ETSZertifikate orientiert. Dies ist auch schon die einzige Gemeinsamkeit.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In the context of the implementation of the Carbon Border Adjustment Mechanism (CBAM), the direct relationship with the European Emissions Trading System (EU ETS) should be taken into account, particularly with regard to the free allocation granted to facilities within the EU. These criteria can be combined as follows: 1.

Our feedback proposes integrating the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to strengthen the implementation of the Carbon Border Adjustment Mechanism (CBAM). By anchoring emissions data, EU ETS free allocation benchmarks, and foreign carbon price payments through cryptographic hashes, unique identifiers, and Mutual Recognition Agreements, EUTIR enhances verification…

Regarding the adjustment for EU ETS free allocation, the current practice does not sufficiently encourage low-carbon production. The gradual phase-out of free allocations must be accompanied by new mechanisms that reward clean producers. Otherwise, the EU carbon price signal will be weakened, slowing down the transition to low-emission technologies.

Starting in 2027, importers will have two obligations regarding the purchase of CBAM certificates (annual cost) until the August/September deadline. First, they must determine the quantity of certificates to be purchased for 2026 based on 2026 emissions data. The second obligation is to monitor quarterly data to ensure that 50% of the CBAM certificate stock is covered by the quarterly cost.

As Sustainabilios, we provide consultancy services to a wide range of industrial companies in Türkiye on carbon management and CBAM preparedness. Drawing on our field experience, we would like to respectfully submit the following observations and recommendations: Through our collaboration with industrial companies in Türkiye, we have identified several important risks concerning the interaction between CBAM…

We are an Italian company that purchases products subject to CBAM from a non-EU country. The mechanism for purchasing certificates is still unclear; it's impossible to manage the information to estimate the financial burden our company will face. This is unsustainable. Furthermore, many EU importers would have to rely on consultants or a third-party certifier, which would further exacerbate the economic impact.

We are an Italian company that purchases products subject to CBAM from a non-EU country. The mechanism for purchasing certificates is still unclear; it's impossible to manage the information to estimate the financial burden our company will face. This is unsustainable. Furthermore, many EU importers would have to rely on consultants or a third-party certifier, which would further exacerbate the economic impact.

Regarding free allowances, we hope the following aspects can be clarified: 1. Clarify the granularity of free allowances: Specify whether free allowances are allocated to aggregated goods category or to individual CN code products, as this will inversely affect the granularity of production process division. 2.

CBAM and ETS are in principle instruments with the wrong approach. Making high emissions expensive is wrong. Conversely, this is correct: low emissions in the EU must be rewarded! ETS and CBAM lead to massive price increases of final products produced in the EU. In addition, CBAM is not feasible from the perspective of a wholesaler in the area of the connecting element.

Filed in German · English published by the European Commission

We are an Italian company that purchases products subject to CBAM from a non-EU country. The mechanism for purchasing certificates is complicated and not easy to understand or implement. It is unsustainable. In addition to this expense, many EU importers would have to rely on consultants, which would incur additional costs. There is a risk of completely losing revenue for items subject to CBAM.

The CBAM certificate system, if linked to free allowances, risks becoming an opaque mechanism that favours large consolidated emitters and excludes the most sustainable local solutions. From our experience in the Canary Islands and Latin America, we have seen how cement and road monopolies use these free allowances as a barrier to blocking local materials (limestone sands, polymers for relapses, alternative…

Filed in Spanish · English published by the European Commission