361 submissions from 305 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 418 submissions on this file. Shown here: the 361 from organizations. Not shown: 20 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 37 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
Expert group meeting: Informal Expert Group on the carbon border adjustment mechan — Sale and repurchase of CBAM certificates · 16 Jul 2026
Public feedback open: Sale and repurchase of CBAM certificates · 8 Jul 2026
Implementing act adopted: Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances p · 15 Dec 2025
Implementing act adopted: Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances p · 21 Aug 2025
Who showed up
291 submissions from industry — companies and their trade associations — against 40 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7.3 industry submissions for every one from civil society.
Industry 291Civil society 40Public authorities, academia, other 30
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
168 of 305
in the EU Register
908
full-time lobbying staff
€116.2M+
declared costs a year
592
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 18 Nov 2021 — it ran from 15 Jul 2021.
Bruxelles, le 18 novembre 2021 OBJET : Consultation publique – Position du Québec sur la proposition de Mécanisme d’ajustement carbone aux frontières de l’Union européenne CONTEXTE Le gouvernement du Québec salue l’exercice de consultation publique de la Commission européenne sur la proposition d’un mécanisme d’ajustement carbone aux frontières (MACF), qu’il perçoit comme un souhait de la part de la Commission…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Jernkontorets reg no:32/21 Stockholm 18 November 2021 European Commission Contribution on the proposal for a carbon border adjustment mechanism (CBAM) Jernkontoret represents steel industry in Sweden producing a wide range of steel products and being highly dependent of export to the whole world market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Statkraft is positive to the introduction of the CBAM. As Europe’s largest producer of renewable energy, we are exposed to changes in the policy framework on climate within the EU and the introduction of CBAM affects Statkraft both directly and indirectly.
UNESID, the Spanish Steelmaking and Primary Steel Processing Association views in relation with the proposed Carbon Border Adjustment Mechanism (CBAM) (Several other aspects has been/are going to be commented by Eurofer, the European Steelmaking Association, and the alliance of the Energy Intensive Industries) UNESID welcomes the Commission tying to reduce carbon leakage and a higher impact in climate change by a…
UNESID, the Spanish Steelmaking and Steel transforming Association views in relation with the proposed Carbon Border Adjustment Mechanism (CBAM) (Several other aspects has been/are going to be commented by Eurofer, the European Steelmaking Association, and the alliance of the Energy Intensive Industries) UNESID welcomes the Commission tying to reduce carbon leakage and a higher impact in climate change by a proposal…
MINISTÉRIO DAS RELAÇÕES EXTERIORES REPÚBLICA FEDERATIVA DO BRASIL O governo brasileiro tem acompanhado com atenção os desdobramentos da proposta legislativa intitulada "Fit for 55", apresentada em 14/7, em que, dentre outras medidas, a Comissão Europeia propõe a adoção de regulamento para a criação de um mecanismo de ajuste de carbono na fronteira (CBAM, na sigla em inglês).
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Feedback to proposal for a Carbon Border Adjustment Mechanism November 2021 Sandbag welcomes the opportunity to provide feedback on the Fit-For-55 Proposal for establishing a Carbon Border Adjustment Mechanism. We are supportive of a carbon border adjustment mechanism (CBAM), as an urgent alternative to the free allocation of emission allowances under the EU’s Emissions Trading System.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bellona Europa hereby submit its consultation response, strongly supporting the European Commission efforts to establishing a CBAM. Our two main recommendations provided below, full details and supporting documentation in attachment. 1. Quicker Phase-out of Free Allocation of EU ETS Allowances is Necessary for Ensuring the Timely Success and Effect of the CBAM 2.
UNIDEN would be welcome a comprehensively designated CBAM addressing all aspects of trade competitiveness UNIDEN invited the Commission to try to safeguard the international competitiveness of the relevant sectors in light of asymmetric climate ambitions and policy implementation of the EU combined to the rest of the world.
Filed in French · English published by the European Commission
R. Marquês Sá da Bandeira, 74, 2º 1069-076 Lisboa, Portugal Tel. [phone removed] Fax. [phone removed] E-mail. [email removed] http://www.celpa.pt Position CELPA Portuguese Pulp and Paper Association Date: 18 november 2021 Comments on the EU Commission proposal for a regulation establishing a carbon border adjustment mechanism Subject: The EU Commission Proposal for a Carbon Border Adjustment Mechanism (CBAM) was…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Europe’s airlines are fully committed to decarbonize air transport and are accelerating their efforts to make Europe the world’s first carbon-neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, and through mitigation.
Government of Canada Comments: Proposal for a regulation establishing a Carbon Border Adjustment Mechanism November 18, 2021 European Commission Brussels, Belgium The Government of Canada is pleased to provide the following comments to the European Commission’s consultation on the proposal for a regulation of the European Parliament and of the Council establishing a Carbon Border Adjustment Mechanism (CBAM).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
For more than 90 years, Boliden has been exploring for, extracting and processing metals and precious metals based on experience, innovation and modern technology. We are a part of the non-ferrous metals industry and our main products are zinc, copper, lead, nickel, gold and silver. Boliden supports the European commission´s increased climate ambition announced in the European Green Deal.
Aurubis welcomes the opportunity to provide feedback on the CBAM proposal. Aurubis is a leading worldwide provider of non-ferrous metals. We process complex metal concentrates and diverse recycling raw materials. Aurubis is a global leader for copper recycling. The Commission has chosen not to include the copper sector in the scope of the proposed CBAM.
Consultation response Commission proposal for a carbon border adjustment mechanism AmCham EU speaks for American companies committed to Europe on trade, investment and competitiveness issues. It aims to ensure a growth-orientated business and investment climate in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Properly designed, a CBAM mechanism can be an important step towards levelling the playing field for European industry against competitors outside the EU. In addition, CBAM can play a role in the global climate transition needed to achieve the objectives of the Paris Agreement. For these reasons, Svemin is in favour of a CBAM mechanism.
Dear Sir/Madam, Business and Science Poland (BSP) welcomes the possibility to comment on the proposal for the Carbon Border Adjustment Mechanism (CBAM) Regulation. Business and Science Poland (BSP) represents entities operating in chemical, refinery, energy, fertilisers, metals and mining, postal services, transport and financial sector, employing over 100 thousand employees in Poland, other EU Member States, as…
Edison’s response to the public European Commission’s consultation on the proposal for a Carbon Border Adjustment Mechanism (CBAM) Edison welcomes the possibility to share its considerations on the European Commission (EC)’s proposal for a Carbon Border Adjustment Mechanism (CBAM).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SNAM’S FEEDBACK ON THE FIT FOR 55 PACKAGE Snam welcomes the Fit for 55 proposals, which overall certainly represent a complex and comprehensive initiative stemming from the Climate Law. In this note, we wish to express some high level comments outlining the most relevant positive elements in the proposals, together with the main areas for development, highlighting where relevant specific aspects across the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EXCA FEEDBACK ON THE PROPOSAL FOR A CARBON BORDER ADJUSTMENT MECHANISM (CBAM) 10 November 2021 The European Expanded Clay Association (EXCA) welcomes the opportunity to provide feedback on the revision of the EU Carbon Border Adjustment Mechanism (CBAM). EXCA represents the major expanded clay producers throughout Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
Proposal on CBAM is one of all Fit for 55 package initiatives that will directly damage the Ukrainian economy. Furthermore, it contradicts the principles of proportionality and subsidiarity since the proposal's goals can be achieved by the existing instrument – the Association Agreement between Ukraine, from one side, and the European Union and its Member States from another side.
It is noted that fertilisers are among the products falling within the scope of the European Commission’s proposal for a regulation establishing a carbon border adjustment mechanism. The EU is heavily dependent on fertiliser imports from third countries, where there is a sharp rise in prices that agricultural producers have to bear.
[phone removed] [email removed] www.plasticsrecyclers.eu Avenue de Broqueville 12 1150 Brussels – Belgium 18 November 2021 Subject: Proposal for a Regulation - Carbon Border Adjustment Mechanism Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the proposal for a Carbon Border Adjustment Mechanism (CBAM) as an opportunity to establish a system where a level…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sir/Madam, APQuímica, the Portuguese Petrochemical and Refination Association, presents in the attached document its comments and contributions under the “Fit for 55” legislative package, and in particular with regard to the proposal for a new CBAM Regulation (CBAM).
Filed in Portuguese · English published by the European Commission
Comentários da Confederação Nacional da Indústria sobre a proposta da Comissão Europeia de mecanismo de ajuste de carbono na fronteira A Confederação Nacional da Indústria (CNI) agradece a oportunidade de apresentar seus comentários acerca da proposta legislativa europeia de mecanismo de ajuste de carbono na fronteira (CBAM). A CNI é a principal representante da indústria brasileira.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Fit for 55 – DVF Rückmeldung zu den Kommissionsvorschlägen: CO2-Grenzausgleichssystem (CBAM) 18. November 2021 Grundsätzliche Bewertung des Fit-for-55-Paketes • Das DVF unterstützt mit Nachdruck die Zielsetzung, Europa bis zur Mitte des Jahrhunderts klimaneutral zu machen. Dazu müssen die Emissionen des Verkehrssektors schon in den kommenden zehn Jahren sehr deutlich gesenkt werden.
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)
Proposal for a regulation EU Green Deal (carbon border adjustment mechanism) Remarks With regard to the proposal of establishing a CBAM, AVE would like to use this opportunity to address selected concerns in this very regulation. The intention is thereby to ensure a uniform interpretation and deployment respectively to ensure preparedness if CBAM is extended to other goods and/or elements of the supply chain.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Build Europe agrees with the creation of a new mechanism – such as the Carbon Border Adjustment Mechanism – to prevent the risk of carbon leakage from third countries and to create a level playing field between EU and non-EU producers.
The progressive phasing out of ETS free allowances and phasing in of a WTO-compliant CBAM: a necessity for stepped-up decarbonisation while providing for an international level-playing field In the EU ETS revision and CBAM proposals, Hydrogen Europe welcomes: • The planned decreasing share of free allowances; • The eligibility of renewable and low-carbon hydrogen to free allowances; • The introduction of…
Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
6 October 2021 Carbon Border Adjustment Mechanism (CBAM) Proposal Position Paper of the European Non-Ferrous Metals Sector This paper provides the initial reaction of Eurometaux to the EU’s carbon border adjustment mechanism (CBAM) proposal. Eurometaux represents European non-ferrous metals producers. Amongst non-ferrous, the aluminium sector is included in the list of CBAM sectors for Phase 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As previously exposed, FEAD welcomes the European Commission’s proposal for a carbon border adjustment mechanism (CBAM) as a complementary tool to the EU ETS and the overall EU environmental legislation, to counteract the risk of carbon leakage. In principle, EU regulations aimed at making the economy more circular constitute increased costs along the whole product life cycle.
To: DG Taxud Date: November 18 2021 The Carbon Border Adjustment Mechanism (CBAM) Proposal – Alcoa public consultation response About Alcoa Alcoa is a global leader in the production of bauxite, alumina and aluminum products. In Europe, the company operates in Spain, Norway and Iceland, with four aluminum smelters and one alumina refinery.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, welcomes the opportunity to provide comments in response to the public consultation on the European Commission’s proposal on EU Carbon Border Adjustment Mechanism (CBAM).
The Romanian Oil and Gas Employers’ Federation’s (FPPG) opinion on the Carbon Border Adjustment Mechanism The “Fit for 55” legislative package constitutes an important building block for the strong foundation needed to achieve a comprehensive decarbonization of the European economy towards 2050.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Teréga welcomes the "Fit for 55" package presented by the European Commission (EC), and wishes to propose several recommendations and areas for improvement to make the Fit for 55 package even more effective. The attached document shortly highlights Teréga’s main attention points in order to make sure that the net-zero objective set by the EC is reached as swiftly as possible and at the lowest-possible cost for the…
STELLUNGNAHME CO2-Grenzausgleichsmechanismus (CBAM) Die Europäische Kommission hat am 14. Juli 2021 im Rahmen ihres Fit-for-55-Pakets die Einführung eines CO2-Grenzausgleichsmechanismus (Carbon Border Adjustment Measure – „CBAM“) vorgeschlagen. Aus der Gruppe der Nichteisen(NE)-Metalle soll zunächst Aluminium einbezogen werden. 1.
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)
WISE, World Information Service on Energy Netherlands, welcomes the opportunity to participate in the consultation on the carbon border adjustment mechanism (CBAM) as part of the EU Green Deal. WISE supports the increased ambition in reducing greenhouse gas emission by 2030 and towards climate neutrality by 2050 through the EU ETS.
Stellungnahme Vorschlag für ein CO2-Grenzausgleichssystem Der Verein Deutscher Zementwerke e.V. (VDZ) begrüßt die Initiative der EU-Kommission zur Schaffung eines CO2-Grenzausgleichssystems (Carbon Border Adjustment Mechanism, CBAM).
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)
We would like to thank the European Commission for this opportunity to comment on the draft Regulation on CBAM. Although DTEK mostly operates outside of the European Union, our activities are closely connected with European Union energy markets.
The EU CBAM is a promising first step to address the urgent problem of carbon leakage. However, the CBAM can only push countries to decarbonise under certain conditions: if firms exporting to the EU have both the means to decarbonise and the ability to track and report emissions.
The Enel Group fully welcomes the Proposed Carbon Border Adjustment Mechanism (CBAM) as a mean to strengthen the EU’s carbon leakage management system and therefore safeguard the competitiveness of EU’s industry.
The EU needs effective means to prevent carbon leakage and level the playing field. Finnish Steel and Metal Producers (Metallinjalostajat ry) believes that carbon leakage should be tackled first and foremost through the present emissions trading mechanism. CBAM-mechanism should be explored in the EU and considered as a complementary measure if the climate ambition between the EU and the rest of the world prevails.
Připomínky Hospodářské komory ČR k návrhu NAŘÍZENÍ EVROPSKÉHO PARLAMENTU A RADY, kterým se zavádí mechanismus uhlíkového vyrovnání na hranicích Revize EU ETS v kombinaci s CBAM by měla mít následující priority: Dosažení daného cíle nákladově nejefektivnějším způsobem, tj.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BASF appreciates the EU Commission’s assessment that new/complimentary policies are critical to protecting EU energy-intensive and trade-exposed industries from carbon leakage, providing incentives for investments in new technologies and allowing for durable business cases in Europe to make the industrial transformation towards a climate-neutral economy work.
Am 14. Juli 2021 schlug die Europäische Kommission die Einführung eines CO2Grenzausgleichsmechanismus (Carbon Border Adjustment Mechanism – „CBAM“) vor. Der CBAMVorschlag hat zum Ziel CO2-Emmissionen innerhalb der EU zu senken, Carbon Leakage zu vermeiden und Drittstaaten ebenfalls dazu zu motivieren klimafreundlichere Regulierungen durchzusetzen. 1.
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)
The European Copper Institute (ECI) is the leading advocate for the copper industry in Europe. ECI supports the EU’s climate ambitions for 2030 and 2050. The Commission has chosen not to include the copper sector in the scope of the proposed CBAM. We welcome this but are concerned about the intention to extend the scope of CBAM in the future to also cover other ETS sectors.
The current CBAM proposed will not be suitable to prevent carbon and investment leakage. We therefore suggest an exclusion of the steel industry from the existing sectors covered by CBAM rules, but at least a five-year test phase of CBAM, without reduction in free allowances during this period.
Carbon border adjustment mechanism – Starch Europe contribution 16 November 2021 – Contribution to the EC open consultation on the legislative proposal Starch Europe acknowledges the legislative proposal on the Carbon Border Adjustment Mechanism (CBAM) as a tool that can contribute to fairer competition on the EU market and prevent carbon leakages.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find FuelsEurope's response to the open public consultation on the CBAM regulation proposal attached to this input. In addition, in the Annex you can find our joint response with other Members of the Alliance of the Energy Intensive Industries on the same consultation.
1 (2) Eeva Korolainen 18 November 2021 Finnish Forest Industries Federation Register ID number: 39671713910-36 Eeva Korolainen, Trade Policy Manager [email removed] Finnish Forest Industries’ response to the consultation on the Carbon Border Adjustment Mechanism (CBAM) Finnish Forest Industries Federation (FFIF) wishes for the FF55 package, including the CBAM, to provide regulatory stability that would promote…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Federacciai “FIT FOR 55” Proposta di revisione della Direttiva ETS e Regolamento CBAM PRIME OSSERVAZIONI FEDERACCIAI L’industria siderurgica italiana ha più che dimezzato le proprie emissioni specifiche di CO 2 dal 1990, condivide gli obiettivi generali del Green Deal UE ed è fortemente impegnata nella ricerca delle soluzioni tecnologiche sostenibili per un’ulteriore progressiva decarbonizzazione dei propri processi…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
SSAB is committed to the European Green Deal vision and Climate Law objective to reduce the EU’s greenhouse gas emissions by at least 55% in 2030 and make Europe climate-neutral by 2050. Our overall goal is to be fossil-free by 2045 at the latest and, as an intermediate goal, reduce our greenhouse gas emissions by 35 percent by 2032 (baseline 2018).
Cerame-Unie feedback on the Proposal for a Carbon Border Adjustment Mechanism (CBAM) 18 November 2021 Cerame-Unie would like to thank the European Commission for the opportunity to submit its feedback on the proposal for a Regulation establishing a Carbon Border Adjustment Mechanism (‘CBAM’).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European heating industry is an essential contributor to the EU 2030 and 2050 climate and energy targets. Through energy efficient, smart and secure net-zero emissions appliances, it can drive the use of renewable energy in our homes and offices, providing cost-effective, advanced technological solutions to achieve the 2030 climate and energy targets and climate-neutrality for buildings by 2050.
Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Novembre 2021 Contribution de la Région Bretagne aux Consultations européennes sur le paquet « Fit for 55 » La Région Bretagne souhaite pleinement prendre sa part à la réalisation des objectifs européens pour une atteinte de la neutralité carbone à l’horizon 2050.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
— The CBAM proposal still contains many ambiguities as a result of the many delegated acts. These should be adopted as soon as possible in order to evaluate the proposal as a whole. — The European Commission should carry out an impact assessment for the 13 policy proposals together. For example, undesirable effects of a combination of measures could be eliminated in advance.
Filed in Dutch · English published by the European Commission
CEE Bankwatch Network welcomes the proposal for the EU's planned CBAM. Our responses to this consultation concentrate specifically on the power sector, based on our experience in southeast Europe, where a CBAM is much-needed.
Our date: 18.11.2021 Consultation on proposal of a regulation establishing a Carbon Border Adjustment Mechanism (CBAM)– response from the Confederation of Norwegian Enterprise (NHO) NHO supports the EU's climate ambitions for 2030 and 2050 and we welcome the EU Fit for 55package, which will be essential for achieving both climate goals and green growth.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurelectric, the sector association which represents the common interests of the electricity industry at pan-European level, thanks the European Commission for the possibility to comment on the proposal for a regulation on the Carbon Border Adjustment Mechanism (CBAM). Eurelectric’s reaction to the CBAM proposal is explained in the uploaded reaction paper. In sum, Eurelectric's key messages are: 1.
1) Solvay would welcome a comprehensive additional instrument to ETS addressing all aspects of trade competitiveness related to carbon leakage Solvay welcomes the intent of the Commission to try safeguarding the international competitiveness of the relevant sectors in light of increasing asymmetric climate ambitions and policy implementation of the EU compared to the rest of the world.
The European Landowners’ Organization (ELO) supports EU’s objective of climate neutrality by 2050, and encourages the EU to adopt measures addressing carbon emissions globally. Additional market mechanisms are necessary to decarbonise industries globally, while avoiding carbon leakage. We particularly encourage the EU to invest in greener industry, at home and abroad, as a part of the CBAM.
The term ‘first mover’ comes from economics and refers to companies that are the first to enter the market with an innovative product or service. In the economy, these companies create new standards and can thus gain significant competitive advantages. However, they also bear a high risk, as innovations or novelties often suffer from childhood illnesses.
Filed in German · English published by the European Commission
We would hereby like to fully support the comments and justifications of Eurofer in its position document & that of Energy-intensive industries (EIIs) (both attached). As such our key messages are as follows: ➢Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and…
The Carbon Limit Mechanism (CBAM) is an important part of the overall effort to ensure a level playing field for the EU’s own operators as part of the implementation of the EU Green Deal. From the perspective of the Central Union of Agricultural and Forestry Producers (MTK), the process highlights the following: 1. The EU tool shall implement this objective at the least possible administrative cost. 2.
Filed in Finnish · English published by the European Commission
We basically welcome the concept to seek for equal treatment of products and services over their value chains, regardless where individual steps of production or service take place. However, it is necessary that real, actual equal treatment is guaranteed.
We fully recognise that the global fight against climate change needs to pick up the pace. Thailand’s recent pledge at COP 26 to achieve carbon neutrality by 2050 and net zero emissions by 2065 reflects a strong ambition in common with the EU’s agenda, even though our target years are different. Such difference is attributable to the financial and technological constraints we face as a developing country.
Glass for Europe, the trade association of Europe’s flat glass sector, welcomes the opportunity to comment on the European Commission’s proposal for a Carbon Border Adjustment Mechanism. The European flat glass sector views its role as the producer of materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe.
Fertilizers Europe welcomes the possibility to share its views on the proposed Regulation of the European Parliament and of the Council establishing a Carbon Border Adjustment Mechanism. Since the idea of a Carbon Border Adjustment Mechanism was launched under the European Green Deal objectives, the fertilizers sector was among the most supportive of this measure.
Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Alfaport VOKA is the platform by and for companies and professional associations in the port of Antwerp, Belgium. Alfaport VOKA is aiming for an accessory, Facilitative, cost-competitive and sustainable port of Antwerp with a view to promoting sustainable employment and added value at the port.
Filed in Dutch · English published by the European Commission
The Ukrainian Business and Trade Association (UBTA) is a Ukrainian non-profit association, accredited in the EU Transparency Register, with a mandate to engage with the EU institutions on behalf of the Ukrainian export-oriented business community.
Fight against climate change is global so for Polish Glass, it is positive that the European Union is considering options encouraging global efforts. CBAM should be introduced in addition to free allocation to preserve the EU sectors’ competitiveness CBAM should not be perceived as an alternative to the free allocation of ETS allowances as both measures address different types of carbon leakage.
Date: 2021-11-18 Our contact: [name removed]. Ares(2021)7093231 - 18/11/2021 Dear Members of the Commission, Thank you for the opportunity to participate in the consultation process on the CBAM proposal. Open communication and transparency are key in the challenging environment of the much needed Just Transition to Net Zero emissions. I. We are Speira: We are an internationally active aluminium company.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
KUBAL is the sole producer of primary aluminium and the largest industrial facility in Sundsvall Sweden. The smelter's capacity has grown more than 10 times since it was launched in 1942. KUBAL's extensive modernization has enabled the smelter to boost production efficiency and reduce the impact on the environment. Half of KUBAL's products is shipped to Swedish customers and the other half goes to clients in Europe.
Tata Steel endorses the Eurofer position on CBAM. Tata Steel would like to emphasise that a proper working CBAM is crucial to ensure the competitiveness of Europe’s steel industry during the process to transition to become carbon neutral. The current proposal does not fully do that. The issue of non-protected EU export sales must be addressed and indirect emissions need to be included.
European Aluminium shares the EU’s ambition of creating a more sustainable economy and welcome the Commission’s determination to combat carbon leakage. While we appreciate that the Commission has recognised the lack of appropriateness of a Carbon Border Adjustment Mechanism (CBAM) to deal with complex issues such as indirect carbon emissions, which in Europe differ from indirect carbon costs, and only foresees a…
The Technology Industries ry has committed to Finland’s carbon neutrality target in 2035 and as part of the European Union’s international climate goals and agreements, such as the Paris Agreement on Climate Change. This requires building long-term climate action so that the EU’s carbon neutrality is achieved in a socially, economically and environmentally sustainable manner before 2050.
Filed in Finnish · English published by the European Commission
The proposed regulation is positioned by the EC as a "mirror image" of the EU ETS in compliance with adopted WTO rules and the Paris Agreement. We suggest that the best practices of the EU ETS should be adopted while finalizing the Regulation inc. the following: 1. The Regulation does not take into account the results of climate projects in accounting for the carbon footprint of goods from 3rd countries. 2.
In the light of the current proposal on CBAM, we would like to reiterate a number of points which are essential to make the instrument both ambitious in terms of climate policy from our point of view and, at the same time, to be particularly cautious with regard to the countries of the Global South.
Filed in German · English published by the European Commission
With “Fit for 55”, the Commission has presented a comprehensive package of 13 pieces of legislation with the objective of reshaping the EU's climate policy on a large scale. BMW Group is convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation.
Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EDF’s feedback on the Commission Proposal of a Carbon Border Adjustment Mechanism European Commission ex post consultation • • • • • • EDF welcomes the Commission Proposal of a Carbon Border Adjustment Mechanism. This climate tool sets the smart principle of an incentive for importers to decarbonize products entering the European Union.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
UNIFA welcomes the possibility to share its views on the proposed Regulation of the European Parliament and of the Council establishing a Carbon Border Adjustment Mechanism. Since the idea of a Carbon Border Adjustment Mechanism was launched under the European Green Deal objectives, the fertilizers sector was among the most supportive of this measure.
The Carbon Border Adjustment Mechanism (CBAM) could offer a better hope of decarbonisation in energy-intensive industries than free allowances, and could create a first-mover advantage for EU industry in the global race to decarbonisation.
Comentários sobre a Proposta de um Mecanismo de Ajustamento das Fronteiras de Carbono (CBAM) A Associação Portuguesa das Indústrias da Cerâmica e da Cristalaria (APICER) gostaria de agradecer à Comissão Europeia pela oportunidade de apresentar o seu comentário sobre a proposta de Regulamento que estabelece um Mecanismo de Ajustamento das Fronteiras de Carbono ("CBAM").
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
NLMK: About Us NLMK is an international steelmaker with a total production of 17 million tonnes. It has a strong footprint in Europe, with six production facilities across Belgium, Denmark, France and Italy directly employing 2,000 people and investments over €1 billion to date. NLMK business model is unique: it is a steel “reroller”.
The TIC Council, as the voice of international independent third-party testing, inspection, certification and verification organisations, welcomes the Commission’s intention to limit carbon leakage. Firstly, we welcome the fact that the total of embedded emissions would be verified by an accredited independent conformity assessment body (Article 8).
Bld. Brand Whitlock 114 / B-1200 Brussels T: [phone removed] [name removed] [email removed] The CBAM proposal risks negative environmental impacts and it is unfair to European manufacturing A negative environmental impact, as a result of ETS and CBAM proposals APPLiA represents the Home Appliance industry in Europe and, as a leader in sustainability, fully supports the EU’s 2050 decarbonisation target.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.
Exmos. Senhores Please find enclosed the position paper of the Confederation of Enterprises of Portugal (CIP) on the proposals to revise the EU ETS and the carbon border adjustment mechanism. We believe that the 2 instruments should be analysed together. Yours sincerely, [name removed] CFSP
Filed in Portuguese · English published by the European Commission
Glass Alliance Europe input to the Public Consultation on the Carbon Border Adjustment Mechanism Proposal. Glass Alliance Europe (GAE), the European Alliance of Glass Industries, welcomes the opportunity to provide feed-back on the Commission proposal to introduce a Carbon Border Adjustment Mechanism. Given the 4,000 characters limitation, this input will focus on the main elements.
We appreciate the efforts and approach of the EC on reducing CO2 emissions and support the EU’s goal of climate neutrality by 2050, recognising this will require breakthrough technologies, significant investments, and an enabling policy framework. REPSOL favours a globally consistent and meaningful carbon price.
Luossavaara-Kiirunavaara AB (LKAB) is an international high-tech mining and mineral group that mines and processes iron ore in Sweden for the global steel market. More than 80% of the iron ore produced in Europe comes from LKAB’s mines.
IEEP's feedback to the European Commission's Carbon Border Adjustment Mechanism proposal The European Commission’s proposal for a European Carbon Border Adjustment Mechanism (CBAM) was released on 14 July 2021 as part of the Fit-For-55 legislative package aiming to achieve a 55% reduction in EU’s GHG emissions by 2030 compared to 1990 levels.
FEVE , The European Container Glass Federation, welcomes the opportunity to provide feed back on the Commission proposal to introduce a Carbon Border Adjustment Mechanism. Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution.
AEGIS Europe’s membership is committed to participate in the emissions reduction efforts. However, given that EU’s international trading partners do not have the same level of climate ambition, EU policymakers need to ensure that the EU’s high climate ambition does not result in carbon leakage.
COCERAL feedback on the proposed Carbon Border Adjustment Mechanism (CBAM) regulation COCERAL, the European association of trade in cereals, oilseeds, pulses, olive oil, oils and fats, animal feed and agrosupply welcomes the EU's Green Deal agenda and its objective to achieve carbon neutrality in the EU by 2050.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Opinion of Kibar Group on Carbon Border Adjustment Mechanism Kibar Group which was established in 1972, today operates in various fields such as metal, automotive, packaging, building materials, construction, logistics, energy, food and service sectors. Our group has 22 companies and 20 production facilities.
The Russian Union of industrials and entrepreneurs (RSPP) is a nationwide public organization that brings together thousands of Russian leading companies, including those that have significant international and European footprint or involved in the international value chains that are part of the EU industrial ecosystem.
CCOO del Hábitat welcomes the Commission’s draft Regulation on CBAM as a significant step in creating a level playing field between EU and non-EU cement producers. The European cement industry is exposed to carbon leakage both at the EU’s land borders and ports. Clinker produced in non-ETS countries will become increasingly competitive, if these countries do not incur the same level of CO2 costs.
Polish Steel Association is a non-profit trade organization of steel manufacturers and steel processing plants that represents Polish steel industry. We support all initiatives supporting energy-intensive sectors of the European industry.
Please find attached our position paper concerning CBAM and some comments on the ETS review related to CBAM for your information: The reinforcements to be implemented in the Emissions Trading System (ETS) are even more stringent than previously adopted.
Filed in German · English published by the European Commission
KPMG Comments on the proposal for a Regulation establishing a carbon border adjustment mechanism KPMG Member Firms in the EU 1 are pleased to provide comments on the proposal for a Regulation establishing a carbon border adjustment mechanism released on 14 July 2021 (the “CBAM Regs”).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Association UKRMETALURGPROM welcomes the European Green Deal and the European Union climate objectives on reducing greenhouse gas emissions by 2030 and achieving climate neutrality by 2050 in Europe. Please find our comments in the attached file. Best regards.
The Carbon Border Adjustment Mechanism (CBAM) Proposal Article 4 of the Customs Union (Ankara) Agreement, which is still in force between the European Economic Community and Turkey, states that “Import or export customs duties and charges having equivalent effect shall be wholly abolished between the Community and Turkey on the date of entry into force of this Decision.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The CBAM proposal raises a number of concerns. • Need for integration with the EU ETS revision: the carbon border adjustment mechanism that is intended to protect industry sectors from carbon leakage regarding imports will start after 2025, but the measures envisioned under the EU ETS revision will come into effect by 2023, or even earlier if implemented retroactively.
EXECUTIVE SUMMARY The Hyundai Motor Group supports environmental goals and considers that the proposed Regulation for a Carbon Border Adjustment Mechanism [“CBAM”] should take into account the climate initiatives of countries such as the Republic of Korea [“ROK”] which has a mandatory Emissions Trading System [“K-ETS”] since 2015. The K-ETS covers ~73.5% of national greenhouse gas [GHG] emissions, i.e.
RE: EU GREEN DEAL (CARBON BORDER ADJUSTMENT MECHANISM): FEEDBACK FOLLOWING THE COMMISSION’S ADOPTION COMMENTS BY POSCO 17 November 2021 European Commission Rue de la Loi 200 1000 Bruxelles Belgium Via European Commission website portal 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Government of the Republic of Korea (the “Government of Korea”) welcomes the opportunity to submit its comments on the European Commission (the “Commission”)’s Proposal for a Regulation of the European Parliament and of the Council establishing a carbon border adjustment mechanism (the “CBAM Proposal”).
KOSA′s KOSA ′s Opinion on the EU CBAM Measure Nov. 17, 2021, The Korea Iron & Steel Association (KOSA) <Opinion> The Korea Steel Association, which represents the Korean steel industry, has a total of 44 steel companies and distributors as members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The CEA welcomes the European Commission’s ambition to establish a carbon border adjustment mechanism. Such a mechanism is essential to preserve the competitiveness of European industries against different decarbonisation pathways between the EU and its trading partners. The CEA would like to draw the Commission’s vigilance on a number of points.
Filed in French · English published by the European Commission
FACE's initial position that inclusion of unwrought primary aluminium (PA) into the scope of the CBAM would be contrary to the European Green Deal and CBAM goals is now even stronger. With regard the EU downstream aluminium subsector, the CBAM might be acceptable, provided that it applies to downstream semi-finished or finished products in full compliance with WTO rules.
The EC proposal on CBAM risks to disproportionally affect developing countries, and, as a consequence, increase inequality and undermine the efforts of poor countries to become greener. The poorest and marginalized people are already the most hardly affected by the climate crisis and the least responsible for the CO2 emissions.
Glass Alliance Europe input to the Public Consultation on the Carbon Border Adjustment Mechanism Proposal. 8 November 2021 Glass Alliance Europe (GAE), the European Alliance of Glass Industries, welcomes the opportunity to provide feed-back on the Commission proposal to introduce a Carbon Border Adjustment Mechanism. Given the 4,000 characters limitation, this input will focus on the main elements.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Currently, the EU protects its sites from carbon leakage through free allowances under the EU Emissions Trading Scheme (EU ETS). The European Commission is now proposing to phase out free alowances and replace them with a Carbon Border Adjustment Mechanism (CBAM). However, in its present form such a "climate tariff" does not offer equivalent protection against delocalisaitons.
Posicionamiento del Clúster Bananero del Ecuador sobre el Mecanismo de Ajuste de Carbono en Frontera. 16 de noviembre de 2021 Introducción La Unión Europea importó, en 2019, un total de 3.24 toneladas de productos orgánicos, lo que representa un incremento de un 0.4% respecto al año anterior. Las importaciones agroalimentarias orgánicas de la UE representan un 2% del total de importaciones agroalimentarias.
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Views of the Turkish Steel Industry on the Carbon Border Adjustment Mechanism (CBAM) Proposal Article 4 of the Customs Union (Ankara) Agreement, which is still in force between the European Economic Community and Turkey, states that “Import or export customs duties and charges having equivalent effect shall be wholly abolished between the Community and Turkey on the date of entry into force of this Decision.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Plant of Portoscuso (SU) Proposal of European Regulation establishing a Carbon Border Adjustment Mechanism (CBAM) – COM (2021) 562 final of 14.7.2021 Revision: 00 Date: November 2021 File name: EA_Feedback on CBAM 52044 Cortona (AR) – Piazza Duomo, 1 - Tel.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
VIK begrüßt die Möglichkeit, an dieser Konsultation teilzunehmen. Die geplante Reform des Emissionshandels sowie der Anstieg der CO2-Preise erhöhen die Notwendigkeit eines starken Carbon-Leakage-Schutzes für die Industrie. Die bestehenden Instrumente werden mit hoher Wahrscheinlichkeit langfristig nicht ausreichen, um die Wettbewerbsfähigkeit des Industriestandortes Deutschland und der EU sicherzustellen.
KITA and KBA Europe (henceforth, KITA) considers that the CBAM raises serious legal and practical concerns. In particular, despite aspirational assertions to the contrary, KITA is concerned that the CBAM appears to be inconsistent with the EU’s obligations under WTO law.
Fit-for-55 Package Initial reaction September 2021 We provide herein our initial reaction to the Fit-For-55 Package about some priority issues for the Italian Business sector, provided that sector’s specific positions are still under definition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Federation of European Private Port Companies and Terminals FEPORT reply to the public consultation regarding the Commission proposal for a Regulation establishing a Carbon Border Adjustment Mechanism (CBAM) Introduction FEPORT is the European association which represents the interests of 1225 private companies and terminals performing cargo handling and logistics related activities in the seaports of the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EU can and should play a leading role in climate policy. Until a global emissions trading system is established, however, exceptionally ambitious EU climate targets could lead to competitive disadvantages for European industry in global trade.
The Carbon Border Adjustment Mechanism (CBAM) proposal is not an adequate solution to the risk of carbon leakage. In this form, it will have a major negative impact on the EU industry and, ultimately, an increase in global emissions.
GENERAL COMMENTS: • Carbon leakage is already a reality and the risk is likely to increase in the view of the raising of the EU climate ambition. • Taking into account the increased EU climate ambition, there is a strong need to appropriately address carbon leakage in order to maintain level playing field for EU producers when competing domestically and on global markets.
The Spanish Association of Independent Cement Importers (ASEINCE) supports the objectives of the European Green Deal as well as the “Objective 55” package of measures aimed at reducing net greenhouse gas emissions by at least 55 % by 2.030.
Filed in Spanish · English published by the European Commission
Neova Group welcomes the Commission’s proposal for a Carbon Border Adjustment Mechanism (CBAM) and sees the proposed mechanism as a necessary tool in preventing the very real risk of carbon leakage. Neova argues that activated carbon should be subjected to carbon pricing via CBAM. Activated carbon is used in air and water purification and in industry it is used to treat waste waters and flue gases.
The European Sustainable Business Federation - Ecopreneur.eu - welcomes the European Commission’s initiative of a Carbon Border Adjustment Mechanism (CBAM) as we consider it to be an important instrument to counteract the risk of “carbon leakage” and unabated greenhouse gas emissions.
Comments on the EU Commission proposal for a regulation establishing a carbon border adjustment mechanism – for external use This document sets out Cepi’s views that complement Cepi’s earlier comments (Response of Cepi to the European Commission Public Consultation on the Carbon Border Adjustment (28 October 2020) and the Cepi comments on the EU Commission inception impact assessment (31 March 2020)) As the EU…
Aughinish Alumina Ltd Feedback on the Carbon Border Adjustment Mechanism legislation proposals Executive summary Aughinish Alumina (AAL) is own by Rusal and AAL is the largest alumina refinery in Europe. Based on Ireland’s West Coast, it is also the one of the largest energy consumer in the country. AAL operates in the 5% lowest carbon intensity within the alumina industry globally.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As a key EU aluminium industry player RUSAL maintains its position expressed within previous consultations on the CBAM as RUSAL still sees no rationale behind the decision to include primary aluminium (PA) into the scope of the CBAM.
CLEPA is pleased to provide feedback on the proposed regulation for a carbon border adjustment mechanism. CLEPA represents over 3.000 automotive suppliers, investing over €30 billion yearly in R&D. Automotive suppliers directly employ 1.7 million people across the European Union and are indirectly responsible for employment of hundreds of thousand of people in upstream industries.
According to the German steel industry, the primary objective of European climate policy should first be to promote an international CO2 price. Internationally harmonised CO2 pricing is a crucial framework for the steel industry to combine ambitious climate protection and international competitiveness.
Filed in German · English published by the European Commission
Climate policy must always take into account the need to ensure the supply of energy, in particular electricity, at all times and in every place. The importance of a continuous supply of electricity, but also its challenges, cannot be overestimated. Energy must also be available at costs that enable European industry to compete on global markets in a sustainable manner.
Filed in German · English published by the European Commission
Carbon Border Adjustment Mechanism MEETING (CBAM) MINUTES Ref. Ares(2021)6900778 - 10/11/2021 UNIFE position paper November 2021 Executive Summary As one of the most energy-efficient transport modes, rail has a key role to play in the overall climateneutrality goal by 2050, which has been enshrined into legislation through the Climate Law.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
European Association of Mineral raw materials Industries, Metal Ores & Industrial Minerals European Carbon Border Adjustment Mechanism (CBAM) Euromines Position The future carbon border adjustment mechanism should be designed in such a way as to address the risk of carbon leakage while fully complying with World Trade Organization rules, maintaining the competitiveness of the European industry and rewarding…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Electricity Futura supports the proposal for a CBAM to strengthen measures to combat carbon leakage and safeguard the competitiveness of EU industry (Articles 1 and 2). The inclusion of the electricity generation sector, which is subject to the ETS and without free allowances, is well placed to be incorporated into the CBAM (Annex I).
Filed in Italian · English published by the European Commission
November 05, 2021 Response to the public consultation on the proposal for a Carbon Border Adjustment Mechanism (CBAM) Sonae is a multinational corporation managing a wide portfolio of businesses in retail, financial services, technology, wood-based panels, shopping centres and telecommunications, creating value across several geographic areas.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Spanish association of magnesia manufacturers (MAGES) appreciates the opportunity to provide its considerations on the proposed Regulation to establish a Carbon Emission Border Adjustment Mechanism. While the magnesia industry supports the concept of a Carbon Border Adjustment Mechanism (CBAM), we want to stress the need for a holistic approach to ensure consistency in the implementation of the different…
Filed in Spanish · English published by the European Commission
The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on strengthening the carbon border adjustment mechanism (CBAM). We believe that the CBAM should be linked with the EU ETS by way of matching the price of import certificates with the price of emission allowances.
MOL Group has a strong ambition to make improvements in its operation that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. Hence, MOL Group welcomes the European Commission’s proposal for the introduction of a Carbon Border Adjustment Mechanism (CBAM).
FNADE, the French waste management and environmental services association, considers that the Commission’s proposal to set up a carbon border adjustment mechanism falls short of the tremendous opportunities that such a mechanism could have created. FNADE regrets the approach is only sectoral and not linked to the carbon content of products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
we welcome the implementation of a Carbon Border Adjustment Mechanism, as it is an important tool to ensure emissions reductions on a global scale. Particularly positive that electricity is covered by the mechanism since it is a sector subject to unfair competition from outside the EU.
Yara welcomes the introduction of a CBAM for fertilizer imports, but believes export levelling mechanisms deserve a fair evaluation. EU exporters like Yara are already challenged by a globally competitive market where supply & demand for commodities determine the price.
Vattenfall strongly supports the EU’s target of becoming a climate-neutral economy by 2050. To reach the Paris Agreement’s 1.5 °C goal, other regions must move in the same direction, though we recognise that it will be done in different pace and by different policies.
Our views Even if polymers are not in the currently proposed scope, they could be considered in a later stage; in addition, certain polymers using some products of the current list as raw materials, such as ammonia, can be impacted by the proposed mechanism in its initial scope.
The EU sugar manufacturing is regulated under the EU ETS and is part of the Carbon Leakage List because of its high trade intensity and its CO2 -relevance. Existing studies show an overall superior environmental and social sustainability performance of EU beet sugar production compared to imported cane sugar, thanks to the efforts made by EU sugar manufacturers.
EUsalt Draft Position on Fit-for-55 Package November 2021 EUsalt - The European Salt Producers’ Association1 - welcomes the Fit for 55 package2, the European Commission’s (EC) roadmap aiming at reducing at least -55% of greenhouse gas emissions by 2030 and at achieving climate neutrality by 2050 in the European Union (EU), in line with the European Green Deal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Commission, Please find Energy Norway's feedback on the CBAM proposal attached. Energy Norway is an association that represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting and trading electricity. Our members produce 130-140 TWh annually, which is around 95 percent of all power production in Norway.
EURACOAL is pleased to submit its attached position paper on the proposed Carbon Border Adjustment Mechanism. Summary EURACOAL cautiously supports the proposed Carbon Border Adjustment Mechanism (CBAM). While it might give some relief to European coal and steel producers by shielding them from global competition that benefits from different social and environmental standards, we are concerned about unintended side…
Freshfel Europe, the European Fresh Produce Association, would like the welcome Commission’s proposal for a Carbon Border Adjustment Mechanism (CBAM) and the exclusion under its scope of the fresh fruit and vegetables sector.
The CBAM as proposed is pragmatic – a sensible approach given the political and economic challenges facing the EU. It shows the art of the possible and is a tool to get the EU to a high universal carbon price. The two critical issues that will be central in the ensuing political debate are the pace at which free allocation is removed without having had an opportunity to test the CBAM under real world conditions, and…
The Polish Electricity Association (PKEE) appreciates the European Commission proposal to establish the Carbon Border Adjustment Mechanism (CBAM) to reduce the risk of carbon leakage and ensure that the price of imports more accurately reflects their carbon content.
On the one hand, it is right for the EU to rapidly reduce its own CO2 emissions and not to wait for other emitters to pursue similar ambitious reduction targets. On the other hand, with high climate protection requirements, the EU is putting at risk the local economy as well as the success of its own efforts, as it risks emigration of value added and emissions to regions with lower constraints (“carbon leakage”).
Filed in German · English published by the European Commission
The European Express Association (EEA) welcomes the opportunity to comment on the proposal for a regulation establishing a carbon border adjustment mechanism (CBAM); we greatly appreciate the consideration given to economic operators and EU citizens as part of this exercise.
The overall target is climate neutrality by 2050. However, it is essential that the measures support decarbonization and climate neutrality and do not mean excessive negative developments for the European economic area as a single effort.
Introduction of a CO2 Border Equalisation Mechanism (CBAM) for steel and steel products of Chapter 72 “Iron and steel” of the nomenclature for foreign trade Dear Sir/Madam, with your proposal for a CO2 border adjustment mechanism (CBAM), cold-rolled strip steels of our industry imported from non-EU countries will in future be subject to a CO2 border adjustment mechanism in 24.32.
Filed in German · English published by the European Commission
PRIMIGEA contribution to the Commission’s public consultation on the Proposal for a Regulation to establish a Border Adjustment Mechanism for Carbon Emissions On 14 July, the European Commission took an important step towards reducing greenhouse gas emissions in Europe.
Filed in Spanish · English published by the European Commission
Mr UPRIGAZ welcomed the main orientations of “Fit for 55”, which should lead to at least a 55 % reduction in GHG emissions by 2030 compared to 1990 levels and to achieving carbon neutrality by 2050. With that in mind, UPRIGAZ supports the principle put forward by the Commission of establishing a carbon border adjustment mechanism (Macf), not only with a view to preventing carbon leakage, but also in order to…
Filed in French · English published by the European Commission
CEMBUREAU welcomes the Commission’s draft Regulation on CBAM as a key opportunity to drive deeper CO2 emissions globally while equalising carbon costs between EU and non-EU suppliers. The European cement industry is exposed to carbon leakage, a trend that will be exacerbated as the EU increases its climate ambition.
HSE Group finds that free allocation of emission allowances transforms competition, are we welcome the proposal to introduce the Carbon Border Adjustment Mechanism, which should ensure that the price of imported products in the EU more accurately reflect their carbon content, and should say by 2036, replacing the free allocation measure in sectors facing a risk of carbon leakage outside the EU.
Filed in Slovenian · English published by the European Commission
Fight against climate change is global so for FOEEiG, it is positive that the European Union is considering options encouraging global efforts. 1. Scope • The list of conditions for applying the CBAM to certain goods shall be specified as regulatory provisions set out in the Regulation.
The revised EU-CO2 pricing will lead to carbon leakage to third countries: production could be located outside the EU and replaced by imports with a higher CO2 footprint. CBAM could turn the table: Instead of reducing emissions inside the EU by ETS, CBAM proposes to impose certificates on the price level of the EU-ETS for imports from third countries with a CO2 emission imbalance.
Iwo Austria is an association that supports the use of liquid fuel heating systems, research and development of liquid fuels and co-design of the transition process from fossil fuels to renewable liquid fuels. The IWO represents the Austrian oil industry and acts as a voice for over 600.000 oil-heater households in Austria, representing around 1,2 million consumers.
Filed in German · English published by the European Commission
* While applying the Border Carbon Adjustment Mechanism, the carbon content of the product should be calculated by taking into account the emissions in the country where it is produced. Before the implementation is put into practice, the carbon trading system in our country should be put into use urgently. Otherwise, Turkey's competitiveness in the EU market will decrease.
EU agriculture and forestry are among the most efficient and advanced in the world in terms of their commitment to the climate and the environment. As professionals in the field, we are and will be the first to be affected by climate change.
Effects of the climate change are being widely observed in Turkey and are on TÜSİAD agenda’s foreground. In this respect, Paris Agreement and European Green Deal are our strategic priorities. TÜSİAD perceives Green Deal as a model of economic growth focusing on fair and inclusive development for all.
The European Lime Association (EuLA) welcomes the opportunity to provide feedback on the EC proposal establishing a Carbon Border Adjustment Mechanism (CBAM). IMPLICATIONS FOR THE LIME INDUSTRY As CBAM is interconnected with EU ETS, its implications on the lime industry will depend on the success and development of a complex and not yet tested instrument. The results of the pilot phase are extremely relevant.
The IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and behavioural changes.
The Danish Chamber of Commerce’s consultation response regarding a Carbon Border Adjustment Mechanism (CBAM). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Carbon Border Adjustment Mechanism (CBAM).
Cem’In’EU welcomes the opportunity given by the European Commission to comment its proposal regarding the creation of a CBAM. Cem’In’Eu supports the long-term objective of climate neutrality in the EU and its Member States by 2050. The EU’s 2030 climate target should be in line with the objectives of the Paris agreement.
The European cement industry fully supports the objectives of the European Green Deal. As well as the “Goal 55” package aimed at reducing net greenhouse gas emissions by at least 55 % by 2030, as set out in the European Climate Law.
Filed in Spanish · English published by the European Commission
The Swedish Society for Nature Conservation has been given the opportunity to comment on the European Commission’s proposal to introduce a carbon border adjustment mechanism (CBAM). Properly designed, such a mechanism could be an important measure to reduce Sweden’s and the Union’s high consumption-based emissions associated with imports from third countries, in accordance with the polluter pays principle.
Filed in Swedish · English published by the European Commission
Overall: - CBAMs do not offer any carbon leakage protection for European exports, as the instrument only focuses on imports within the EU single market and is therefore not fit to replace current mechanisms under the ETS. In particular export-intensive sectors such as polysilicon will suffer from a major loss of competitiveness in global markets, if free allocation and indirect cost compensation would be phased-out.
The terms and conditions of CBAM mechanism should be well determined, stable, coherent and fair to all countries and must pay regard to reasonable, reliable economic and financial parameters to identify the status of the country as ” developed”, “devoloping” or “underdeveloped” . The support and responsibilities for CBAM seems to be varying with respect to the status.
OPINION OF THE TURKISH ALUMINIUM INDUSTRY ON CARBON BORDER ADJEUSTMENT MECHANISM TALSAD Turkish Aluminium Industrialists Association’s opinion, based on a large membership background is that the aluminum industry should not be included in the EU Carbon Border Adjustment Mechanism (CBAM). The reasoning behind this general consensus among our members are explained below.
August 25, 2021 Directorate-General for Trade European Commission Rue de la Loi 170/[address removed]/Brussel Belgium Dear Madame Director-General, As a supplier to a large number of EU importers of flat rolled aluminium products, Assan Alüminyum believes that the aluminum industry should not be included in the EU Carbon Border Adjustment Mechanism (CBAM) for a number of reasons: • CBAM costs will neither consider…
For us as farmers organisation, the proposed CBAM seems inadequate. Because fertilisers can expect a carbon border tax, they wil probably become more expensive in Europe. However, fertilisers are already more expensive in Europe due to anti-dumping measures.
European Steel Tube Association Association Européenne du Tube d'Acier Boulogne, April 30th, 2020 Inception Impact Assessment: Carbon Border Adjustment Mechanism (CBAM) Response of European Steel Tube Association (ESTA) The Steel Tube industry in EU is because of its industrial and commercial specificities particularly exposed to the risk of carbon leakage.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Paris, 20 avril 2020 NOTE DES AUTORITÉS FRANÇAISES Objet : Réponse des autorités françaises à la consultation publique de la Commission relative aux grandes orientations sur l’étude d’impact concernant le mécanisme d’ajustement carbone aux frontières Réf.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AEGIS Europe is an industry alliance that brings together more than 20 European manufacturing associations representing the whole value chain, committed to Europe manufacturing as the fundamental driver of innovation, growth and jobs in Europe. Our members account for more than €500 billion in annual turnover, as well as for millions of jobs across the EU.
Business and Science Poland (BSP) connects the experience of leading Polish enterprises with the EU agenda. We represent the knowledge and interests of entities which employ over 100 000 workers in Poland, in the EU and globally. We are committed to advancing the values of EU Common Market acknowledging the need to transform it responsibly and effectively.
Comment 1 April 2020 BUSINESSEUROPE COMMENTS CARBON BORDER ADJUSTMENT MECHANISM INCEPTION IMPACT ASSESSMENT BusinessEurope is grateful for the opportunity to provide comments to the inception impact assessment of the carbon border adjustment (CBA) mechanism under the EU Green Deal. CBAs are arguably a sensitive measure and BusinessEurope at this point does not take a position for nor against it.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CEEP is in principle in favour of Carbon Border Adjustment Mechanism which shall create the level playing field for European and non-European producers. Taking into account the increased climate ambitions announced in the European Green Deal but also the process of recovery of the European economies following the COVID-19 outbreak, the equal treatment of EU and non-EU companies is of utmost importance for…
The design and implementation of a border carbon adjustment (BCA) or alternative policy should be guided by policy objectives in light of the potential trade-offs. We believe that strengthening of climate actions by reducing carbon leakage is the main goal since the European Green Deal aims to achieve the climate targets of the Paris Agreement.
The representatives of the Ecuadorian Banana Cluster welcome the possibility to share its general views on Carbon Border Adjustment Measures (CBA) and looks forward to presenting its more detailed feedback during the upcoming public consultation.
The Verband der Deutschen Feuerfest-Industrie e. V. (German Refractories Association) supports the position of Cerame-Unie. The impact assessment should also include the aspect of how the mechanism can preserve the competitiveness of EU products on export markets and should also address the fact that for sectors like the refractory industry the Carbon Border Adjustments do not appear to be neither feasible nor…
Response to the published Inception Impact Assessment for a Carbon Border Adjustment Mechanism Bellona Europa commends the European Commission’s ongoing efforts to ensure that climate neutrality is met by 2050 and efforts to price Greenhouse Gas (GHG) emissions.
CAN Europe views on carbon border adjustment mechanisms: a. Considering the necessity of a CBAM creation does not imply that CAN Europe agrees with the notion that our industry suffers from carbon leakage, as this is still largely unproven.
On behalf of Resources for the Future (RFF), we are pleased to share the accompanying comments to the European Union on Commission Issues Concerning a Possible Carbon Border Adjustment Mechanism (CBAM). RFF is an independent, nonprofit research institution in Washington, DC. Its mission is to improve environmental, energy, and natural resource decisions through impartial economic research and policy engagement.
EU Green Deal – Carbon Border Adjustment mechanism EDF Contribution The Climate Law, published by the Commission on 4 March 2020, includes the goal of climate neutrality for the EU by 2050 and suggests an increased climate ambition to reduce GHG emissions by 50-55% by 2030 from 1990 levels. Reaching these targets is likely to involve a significant increase in EU ETS carbon price that can lead to carbon leakages.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Grupa Azoty supports the introduction of CBAM as it addresses the key gaps in EU ETS system: allowing EU consumption to contribute to increased global emissions, while burdening EU producers with ETS costs. At the same, by failing to incentivize foreign producers to lower their emissions, ETS fails to achieve the key EU objective of lowering global emissions.
The Association of Swedish Engineering Industries welcomes and supports a global decarbonization. Climate change is a global challenge that must be handled in an international context, and we welcome an EU wide and international collaboration. We also believe that European companies are well positioned to be front runners in the green transition.
Minerals, metals and advanced materials have a central role in the green transition, e.g. in the clean energy and transport sector. Ensuring a sustainable supply of raw materials is crucial for Europe's industrial leadership and to achieve a climate neutral, resource efficient and competitive European economy.
KGHM Polska Miedź S.A. is a major scope for more than 50 years. A contribution to the eligibility to provide feedback on the Inclusion Impact Assessment on Carbon Border Adjustment Mechanism (SAM). The design of a carbon border adjustment mechanism and a detailed impact assessment. Due to the innovative nature of this instrument, CBAM should be introduced gradably to include selected actors in the pilot phase.
Filed in Polish · English published by the European Commission
- Carbon Border Adjustment (CBA) would be supplementing the European Climate Policy. It is needed to achieve the long-term ambitions of EU climate policy while avoiding carbon leakage. CBA can also be seen as a temporary tool whereas the long-term target is to have a global price for carbon.
EURACOAL understands that calls for a CBA mechanism are a logical counterbalance to the EU’s stringent, unilateral policies linked to climate action. Currently, EURACOAL has not reached a position on a CBA mechanism. We await concrete proposals, but offer some initial views here in our response paper. 1.
Repsol is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050.
The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to proposal for a “Carbon Border Adjustment Mechanism” Directive. • European economy competitiveness shall continue to be a key goal for EU policy, being strictly linked to employment levels and, in general, to the overall internal wealth.
SUMMARY (full response see attachment) The Roadmap for a Directive on a Carbon Border Adjustment Mechanism names several requirements for such policy. It is expected to ensure that the “price of imports reflect more accurately their carbon content”.
ClientEarth and Ember welcome the European Commission’s initiative to propose a CBAM. This summary is expanded upon in Ember’s attached report; and ClientEarth’s and Ember’s joint attached briefing, both of which form part of our submission. Scope of the CBAM The main objective of the CBAM is to fight climate change by tackling carbon leakage.
• The European Union should continue to lead the way in the global fight against climate change, both with domestic action and leading negotiations at international level. The EU should pursue an ambitious implementation of the European Green Deal, including the goal of climate neutrality by 2050 and a package of enhanced policies and measures to accelerate the transition to a low carbon economy.
UC Rusal is the 3rd largest global primary aluminium (PA) producer. Rusal meets 20 % of the EU growing PA demand 75 % of which is imported. Rusal’s PA and PA alloys are subject to the EU import duties of 3-6 %. Aluminium sector with 1.1 Gt CO₂ e accounts for 2 % of global anthropogenic emissions. Rusal measures carbon footprint of its operations and supports industry-wide decarbonisation.
[see attached file for full response] IFIEC Europe’s response to the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM) Improving carbon leakage protection of the European Union Executive summary In December 2019, the European Commission adopted the European Green Deal.
In the context of the Covid-19 breakout where European democracies are experiencing situations and measures that had not been seen since World War II, any forthcoming EU policy will need to be adapted to the new societal and economic challenges which will arise in the aftermath of this crisis.
Hydro is a global aluminium company, present in 20 EU/EEA countries, with more than 21.000 employees in Europe and 35.000 globally. Please find attached our contribution. Key messages : Hydro strongly support the importance of preserving the competitiveness of European industries, which is rightly recognized in the Inception impact assessment (IIA) for a carbon border adjustment mechanism (CBAM).
EU GREEN DEAL ON STEEL Ref. Ares(2020)1882704 - 01/04/2020 EU CLIMATE LEADERSHIP REQUIRES WATERPROOF CARBON LEAKAGE MEASURES WHY A CARBON BORDER MEASURE NEEDS TO COMPLEMENT TEMPORARILY FREE ALLOCATION AND INDIRECT COSTS COMPENSATION IN THE TRANSITION TOWARDS CLIMATE NEUTRALITY This paper clarifies the reasons why it is appropriate from environmental, economic and legal perspectives to implement initially a carbon…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Cem’In’Eu supports the long-term objective of climate neutrality in the EU and its Member States by 2050. We welcome the opportunity to provide feedback on the Carbon Border Adjustment Mechanism and thus participate in the building of a successful measure to foster innovation in the cement industry. Indeed, this structural measure must be built on the right design to be a cornerstone of the European Green Deal.
ACV-CSC METEA, for which I am Secretary General, responsible in particular for the steel sector, strongly supports the principle of carbon adjustment at the borders of the European Union. We therefore call for a proactive EU directive and for implementing measures to be taken in this regard as soon as possible.
Filed in French · English published by the European Commission
Climate change is inextricably linked to economic inequality: it is a crisis that is driven by the greenhouse gas emissions of the ‘haves’ that hits the ‘have-nots’. Oxfam estimates of the scale of this inequality suggest that the poorest half of the global population – around 3.5 billion people – are responsible for only around 10% of total global emissions attributed to individual consumption.
Forest industry plays a significant role in mitigating climate change and reaching European Green Deal objectives. The industry offers climate friendly products for European and global markets, also substituting more fossil intensive alternatives. Reaching i.a. climate objectives requires the safeguarding of EU industries' competitiveness and legislative predictability and stability.
1. Solvay welcomes the EU intent to safeguard the competitiveness of EU industries. The EU wants to become the first continent carbon neutral in 2050 which involves a deep turnaround of all the sectors of the EU economy. New climate constraints will nevertheless mean a more severe greenhouse gas emissions (GHGs) reduction path with an increased risk of carbon leakage as underlined by the Commission.
Fuels Europe favours a common CO2 market across the whole economy based on a single carbon price. But until consistency on worldwide carbon pricing and ambition can be achieved, FuelsEurope thus welcomes the EC initiative to examine proposals for mechanisms that would reduce the risk of carbon leakage as the EU increases its climate ambition in the European Green Deal context.
Fuels Europe favours a common CO2 market across the whole economy based on a single carbon price. But until consistency on worldwide carbon pricing and ambition can be achieved, FuelsEurope thus welcomes the EC initiative to examine proposals for mechanisms that would reduce the risk of carbon leakage as the EU increases its climate ambition in the European Green Deal context.
PepsiCo welcomes the opportunity to provide input to the Inception Impact Assessment on the Carbon Border Adjustment Mechanism. One of the world’s leading food and beverage companies with a strong footprint in the EU, PepsiCo strongly supports the European Commission’s Green Deal and wishes to play a key role in helping Europe achieve its climate neutrality by 2050.
The Swedish Society for Nature Conservation (SSNC) supports the concept of fully integrating the external environmental cost of products and consumption, including for goods that are imported to the EU. This is not being done in a satisfactory way today and in many EU countries, including Sweden, emissions per capita are higher than perceived if consumption-based emissions are accounted for.
HYBRIT’s feedback for Carbon Border Adjustment Mechanism HYBRIT is a joint venture project between SSAB, LKAB and Vattenfall to create a fossil-free energy-mining-steel value-chain. HYBRIT recognises and welcomes the European Commission’s goal to achieve carbon neutrality by 2050 – the project is a leading example of a breakthrough technology to produce fossil-free steel.
As a leading independent power producer from renewables in Europe – wind, solar and hydro – ERG Group supports the raising ambitions of European Commission on decarbonization and its determination to tackle this issue globally, also considering the competitiveness of the EU industry with other foreign countries.
In the context of the COVID-19 pandemic, UNIDEN calls for the reindustrialisation of Europe to ensure an adequate supply of technologies and products for European citizens. In this context of crisis, Europe’s industrial strategy should be completely redefined.
Filed in French · English published by the European Commission
The VDA represents the interests of over 600 international companies with 800,000 employees in Germany . With an added value of approximately 130 billion euros per year and a 4.7 percent share of the gross domestic product, the automotive branch is one of the most important industrial sectors in Germany.
The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich, WKÖ) supports the goal of the European Climate Policy to attain climate neutrality by 2050. Given the massive negative repercussions of the current COVID-19 pandemic on the European population, business and industry, all relevant considerations, measures and instruments – including preparations for a possible Carbon Border Adjustment Mechanism…
Please see the summary here and the full position attached: In the context of the Covid-19 breakout where European democracies are experiencing situations and measures that had not been seen since World War II, any forthcoming EU policy will need to be adapted to the new societal and economic challenges which will arise in the aftermath of this crisis.
Aluminium production and its value chain is very much different to other industries which are also exposed to Carbon Leakage, as for instance steel. This leads to numerous complications with regards to how a CBAM could effectively be implemented.
FEAD – the European Federation for Waste Management and Environmental Services, supporting and promoting circular economy in the EU, is in favour of a carbon border adjustment mechanism (CBAM), as complementary to the EU ETS and the overall EU environmental legislation.
Deltalinqs represents the joint interests of more than 95% of all logistics, port and industrial companies in the main port of Rotterdam. More than 700 companies from fourteen different sectors are affiliated with our business association. Together they contribute 6.2% to the Gross National Product of the Netherlands and offer direct and indirect employment to over 385,000 people.
A. Context Cefic welcomes the Commission’s focus on ensuring industry competitiveness for a climate-friendly transition, namely to become climate-neutral by 2050 while ensuring that European companies can globally compete on a level-playing field. Cefic remains a strong supporter of free and fair trade.
1 April 2020 Inception Impact Assessment: Carbon Border Adjustment Mechanism (CBAM) The Response of Eurometaux – The European Non-Ferrous Metals Industry This document gives the reactions from the non-ferrous metals sector - a very electro-intensive sector – to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms (CBAM).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Bioenergy Association of Finland supports the objectives of the EU Green Deal, including climate neutrality by 2050, healthy ecosystems in the EU, improved competitiveness for European industries and higher energy security. Development of carbon border adjustment (CBA) mechanisms requires, however, careful assessment.
Confindustria Ceramica support CerameUnie position paper. We are also looking at that the impact assessment regarding the proposed carbon border adjustment measures. The impact assessment should also include “the mechanism can preserve and the competitiveness of EU products on export markets and should also address the fact that for sectors like the dynamic carbon leakage measures”.
Filed in Italian · English published by the European Commission
The VDMA is critical of a possible carbon border tax. Main points of criticism include high bureaucracy during implementation (how do I measure the CO2 content of an imported product), high level of difficulty in making it WTO-compliant, protectionism provokes countermeasures and this is not good for the open German economy. - Free trade must first and foremost ensure Europe's long-term competitiveness.
Please find attached the feedback of the Association of German Chambers of Industry and Commerce (DIHK). DIHK is the central organisation of 79 Chambers of Commerce and Industry, CCI (Industrie- und Handelskammern, IHKs) in Germany, representing 3.6 million companies from industry, commerce and services.
Starch Europe raised at several occurrences that the stricter environmental policies implemented in the EU weigh on the competitiveness of the EU starch industry globally, and regrets the lack of a global playing field with other trade partners.
A. Context Cefic welcomes the Commission’s focus on ensuring industry competitiveness for a climate-friendly transition, namely to become climate-neutral by 2050 while ensuring that European companies can globally compete on a level-playing field. Cefic remains a strong supporter of free and fair trade.
Fertilizers Europe welcomes the possibility to share its general views on Carbon Border Adjustment Measures (CBAM) and looks forward to presenting its more detailed feedback during the upcoming public consultation. Our main points are the following: 1) Fertilizers Europe wants the fertilizer sector to be evaluated in the CBAM impact assessment study.
The EU Green Deal must become a driver for Europe’s strategy and rebuild the European economy, in the aftermath of the COVID-19 crisis, with decarbonization as the main driver. Achieving climate neutrality will require bold actions to build an ultra-efficient economy and accelerating direct electrification. Within the green deal it is the right moment to reevaluate the carbon pricing instruments.
The EU’s ambitious climate objectives Many energy-intensive industries are key industrial value chains for the European economy and their pathway towards net-zero greenhouse gas (GHG) emissions by 2050 is likely to be challenging. To meet these ambitious goals, the EU will need to ensure that European economies and industries swiftly transition to a low-carbon economy in a cost-efficient way.
The Confederation of Swedish Enterprise sees climate change as a major challenge, one which should ideally be dealt with by introducing a global CO2 price. This should continue to be the overarching goal, but even without such a price, we support the EU ambition to become climate neutral by 2050.
2020 Industrial Affairs Ref. Ares(2020)1875636 - 01/04/2020 1 April 2020 Federación Empresarial de la Industria Química Española – www.feique.org Hermosilla, 31 - 28001 Madrid – Tfno: 91 431 79 64 – Fax: [phone removed] –[email removed] FEIQUE’s comments on the European Commission’s Inception Impact Assessment regarding a C arbon border adjustment mechanism (CBAM) GENERAL COMMENT It is supposed that the study…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
I'm representing the Central Union of Agricultural Producers and Forest Owners (MTK). MTK is an interest organisation representing farmers, forest owners and rural entrepreneurs in Finland. MTK has over 316 000 members in local agricultural producers’ organisations and regional forest management associations. In principle the CBAM could be an excellent measure to avoid carbon leakage in all sectors.
For IndustriAll Europe, increasing the EU climate ambition in a context of global asymmetrical climate policies requires – among other instruments - a Carbon Border Adjustment Mechanism (CBAM) to include imports into the EU Emission Trading System and to exempt exports from the impact of such a scheme.
CARBON BORDER ADJUSTEMENT It is essential that a carbon border adjustment is implemented as a complementary measure in addition to existing carbon leakage provisions in the transition towards climate neutrality. This measure should be applied, in the form of the customs on the imported products. We strongly oppose any other form of tax, fee or any other financial burden levied on the domestic EU production.
Warsaw, 1st April 2020 PGNIG POSITION ON INCEPTION IMPACT ASSESSMENT CONCERNING CARBON BORDER ADJUSTMENT MECHANISM PGNiG welcomes the opportunity to comment on the inception impact assessment concerning Carbon Border Adjustment Mechanism.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The VIK – Verband der Industriellen Energie- und Kraftwirtschaft welcomes the opportunity to comment on the Commission’s impact assessment on the Carbon Border Adjustment Mechanism (CBAM). VIK position on the European Commission’s Impact Assessment for a Carbon Border Adjustment Mechanism The VIK welcomes the European Commission’s initiative to examine how to improve the protection of European industry against…
Filed in German · English published by the European Commission
We appreciate a possibility to deliver views of Climate Leadership Coalition (CLC) regarding a Carbon Border Adjustment Mechanism. CLC supports the climate neutrality target of 2050 for the EU. We also think that the EU ETS is an efficient tool to reduce carbon emissions in the energy and industrial sectors.
The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s work to enshrine the long-term objective of climate neutrality by 2050 in legislation and increase the EU’s climate ambition by 2030. Additional market economy measures are necessary to enable decarbonisation of the industry, while avoiding carbon leakage.
On behalf of the Climate Friendly Materials Platform, Climate Strategies welcomes the consultation and believes that a well-designed policy response is needed to deliver a robust framework for decarbonisation of production and use of basic materials in Europe while avoiding carbon leakage. Please see attached the document with our detailed comments.
The EFBWW fully supports the goals laid down in the European Green Deal and welcomes the European ambitions to achieve climate neutrality by 2050. Today, buildings account for 40% of energy consumed and for about 40% of CO2 emissions. The annual renovation rate of the building stock varies from 0.4% to 1.2% in the Member States.
Carbon Market Watch fully supports efforts to price GHG emissions, within and outside the EU. The EU ETS has been successful for certain sectors, but has failed to incentivise large scale decarbonisation of European industry, in part because of its excessive measures to guard against the hypothetical risk of carbon leakage.
WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V. The steel and metal processing industry calls for a comprehensive protection of competition in the event of the introduction of a border adjustment mechanism, which includes all processing stages of emission-intensive materials.
The European Express Association (EEA) welcomes the opportunity to comment on the Commission’s inception impact assessment on the Carbon Border Adjustment Mechanism (“CBAM”). The EEA agrees with the Commission that it is important to assess the impact of different options and supports the Commission’s climate change objectives.
Border Adjustment – A possible building block to prevent carbon leakage Position paper • The decarbonisation of industry in Europe must not be achieved by replacing domestic production with imports with significantly higher CO2 @-@ loads. Protection against carbon leakage must therefore be a key component of industrial and climate policy.
Filed in German · English published by the European Commission
essenscia agrees that an effective carbon leakage protection tailored to the effective carbon cost burden on competing industries in the rest of the world is crucial in the fight against climate change. The chosen carbon leakage measures need to provide carbon leakage protection for products on the EU market as well as for products intended to export.
Eurelectric represents the European power sector. The association has historically advocated for a robust carbon pricing to deliver substantial GHG emissions reduction across Europe. In the context of greater climate ambitions in the European Green Deal, Eurelectric welcomes the ongoing work of the European Commission and support its investigation for a carbon border adjustment.
As WindEurope we welcome the EU’s commitment to raising EU ambition on decarbonisation. Carbon Border Adjustment would help leverage increased climate ambition from the EU’s trading partners, for instance through the implementation of meaningful emissions reduction mechanisms. It should of course be developed in line with WTO rules, as the Commission has said.
About National Grid Interconnectors National Grid Interconnectors has 50% ownership shares in assets representing nearly 8,000 MW of cross border electricity interconnection capacity between the UK and EU. These assets facilitate delivery of many billions of euros of consumer welfare through lower energy costs, security of supply and the integration of renewable forms of electricity generation.
POSITION PAPER FEEDBACK ON EU CARBON ADJUSTMENT MECHANISM General Views As part of the EU’s Green Deal, European Commission drafted a “Carbon Border Adjustment Mechanism” to reduce the risk of carbon leakage for selected sectors and has initiated public consultation process, to receive feedback from all stakeholders. It is hereby presented following recommendations: - Many non- EU companies (e.g.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Zero Emissions Platform (ZEP) is a European Technology and Innovation Platform (ETIP) under the Commission’s Strategic Energy Technologies Plan (SET-Plan), and acts as the EU’s technical adviser on the deployment of Carbon Capture and Storage (CCS), and Carbon Capture and Utilisation (CCU).
Green Home from Montenegro strongly supports stringent carbon border adjustment mechanism (CBAM) for all ETS sectors, especially electricity production and trade. Montenegro, as a country heavily dependent on coal energy production, is therefore depend on the only thermal power plant it has, located in Pljevlja Municipality – responsible for the major economic, environmental and social issues that Montenegro is…
The Commission proposes to assess the establishment of a carbon border adjustment mechanism in forms and for sectors still to be defined. For CEPM corn producers, carbon is an important issue. It appears as an opportunity thanks to the formidable corn's carbon pump to produce food & feed, store carbon and replace fossil carbon.
The Commission is proposing to assess the introduction of a carbon adjustment mechanism at EU borders in forms and sectors still to be defined. For maize producers at the General Association of Maize Producers (AGPM), the carbon dimension is an important issue. It appears to be an opportunity thanks to the great carbon pump of maize to feed, store carbon and replace fossil carbon.
Filed in French · English published by the European Commission
On 11 December 2019, Commission President Von der Leyen presented her European Green Deal package proposal to the European Parliament. Not surprisingly, it included an upcoming proposal for a "carbon adjustment mechanism at the Union's borders", an innovation designed to align the EU's trade policy with its decarbonisation objective.
Response to the Open Feedback invitation on an inception impact assessment for the implementation of Border Carbon Adjustments. This is Sandbag’s response to the March 2020 open feedback invitation launched by the European Commission on the topic of the introduction of Border Carbon Adjustments (BCAs).
As WWF EPO, we wish to submit the attached statement to answer the inception impact assessment on the Border Carbon Adjustment Mechanism (BCA). Our main arguments are summarized below. 1) If introduced, the BCA must be implemented as an alternative to free allocation and within a wider set of policies to ensure the decarbonisation of industry 2) WWF EPO recognises that the BCA could play different catalyzer roles in…
Environmental Defense Fund (EDF) applauds the European Commission's efforts towards climate neutrality. EDF encourages Europe to leverage its single market to encourage more ambitious global climate ambition and a more pro-climate interpretation of WTO rules.
Change Partnership is a not-for-profit thought-leadership and mission-orientated organisation seeking to solve the politics of the climate crisis. We do not support a carbon border adjustment mechanism on the basis that it: - does not ‘protect’ the EU economy, - is not in the interest of consumers and wider society, and - it does not create the positive political conditions and framework needed to build a global…
This document gives the reactions from the Finnish Steel and Metal Producers to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms. Given the expected potential higher climate ambition for 2030, we recognize that additional and improved carbon leakage provisions may be needed.
Center for Environment from Bosnia & Herzegovina is in favour of a stringent carbon border adjustment mechanism (CBAM) for all ETS sectors, including electricity production and trade. Bosnia & Herzegovina is currently strongly dependent on coal with 70% of electricity coming from thermal power plants, and is planning to add new capacities, with a plan to export coal generated power, including to EU markets.
Réponse d’EpE à la consultation de la Commission Européenne sur le MAC L’association française des Entreprises pour l’Environnement (EpE, www.epe-asso.org) rassemble une quarantaine de grandes entreprises françaises et internationales qui travaillent ensemble à mieux intégrer l’environnement dans leurs stratégies et leurs opérations, et à faire des défis de la transition écologique un moteur de transformation…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
NLMK Group actively supports the existing and potential measures to combat climate change, including by way of decarbonizing the steel sector in the EU and other jurisdictions. With regards to the main objective, we welcome the Commission's endeavour to seek the ways to design the mechanism which can "[fight] climate change by avoiding carbon leakage".
ZPPS contribution on the Inception Impact Assessment on Carbon Border Adjustment Mechanism. 31th of March 2020 ZPPS, Polish Glass Manufacturers Federation, brings together and represents at national and EU-level multinational firms and national companies producing glass and glass articles. ZPPS welcomes the possibility to provide our initial feedback on the Carbon Border Adjustment Mechanism (CBAM).
To Whom It May Concern, We wish to submit the attached in depth response to this consultation. A brief summary of the main arguments is provided below. 1. The EU discussion on anti-carbon leakage measures must not be allowed to distract from the broader objective of putting energy-intensive industry onto a pathway towards climate neutrality by 2050.
The Russian Steel Association represents the largest producers of steel products in Russia, who deliver around 98% of Russian cast iron, 90% of steel from Russian rolled metal, about 60% of pipes and a significant share of industry raw materials. Members of the Association are actively engaged in the international trade importing to the major steel markets, including to the EU.
Attached you can find the feedback that Confcommercio - Imprese per l'Italia, the Italian General Confederation of Enterprises, Professions and Self-Employment as well as the largest employer organization in Italy, has provided on the Commission's Road Map regarding the Carbon border adjustment mechanism - Ares(2020)1350037.
Suggestion of the Ministry of the Development of Economy, Trade and Agriculture of Ukraine Carbon border adjustment mechanism under is extremely sensitive element the Green Deal of the EU which should find delicate balance between different areas of policies, international law rules, economy on social development, including recent COVID-19 outbreak.
Today, France targets carbon neutrality in 2050, which means zero net emissions of all greenhouse gases (GHG). Discussions are also taking place at European level to ensure that the Union has the same objective. This implies a significant change in our decarbonisation rate since French emissions have fallen by only 19 % since 1990.
Filed in French · English published by the European Commission
A carbon border adjustment, or any similar instrument, such as the inclusion of consumption in the EU ETS, is very welcome not only because it prevents carbon leakage, but also because it does so by setting a clear carbon price (or material efficiency) signal for third parties (hence incentivising them to decarbonize), while restoring the incentive to decarbonize European industry which has been lost to a large…
Please find below a summary of the EuLA position for a future Carbon Border Adjustment (CBA). Further information is provided in the attached EuLA position paper: Lime is a key enabling material, active in a number of important industrial sectors, such as steel, cement, non-ferrous metals, paper, glass, etc.
Kayrros (https://www.kayrros.com/), a European company leading in Earth observation analytics, welcomes practical solutions with a global dimension to address the reduction of GHG emission, such as the setting of a carbon border adjustment mechanism. Such a mechanism should be crafted in a way that encourages large-scale long-term investments in a net-zero emissions economy.
Carbon border adjustments (CBA) are the wrong way to support transformation of industry The CBA proposed by the Commission do not help to support the transformation of the industry towards achieving the EU climate goals. The risks and burdens that come with CBAs outweigh by far the opportunities. Moreover, the effectiveness of CBA is questionable.
[name removed] UMB UmweltManagementberatung Hacker GmbH (Environmental Management Consultancy) [address removed], Germany + 49 @-@ 30 @-@ 32000960/ [email removed] Www.umb-hacker.de Opinion on the Carbon border adjustment mechanism – Commission initiative I very much welcome the Commission’s initiative. As Chair of the Federal Association for Emissions Trading and Climate Protection (bvek) e.V.
Filed in German · English published by the European Commission
Laminoirs des Landes (LDL), located in Tarnos, Southern France, a company starting operations in Spring of 2.018, is an independent Carbon Steel Plate re-roller (manufacturer of Plate which purchases a semi-finish product, Slab, and hot-rolls to get the final Plate).
ABN AMRO Clearing Bank (AACB) is a longstanding supporter of the energy transition and has been facilitating the cap and trade system since the introduction. We clearly see the benefits of the current Emissions Trading System, including the strong policy commitment, the effective price formation on the markets as a function of supply and demand, and the increasing certainty that emissions will fall below a…
AFEP, the French Association of Large Companies, welcomes the initiative of the European Commission to launch an inception impact assessment on a possible carbon border adjustment mechanism. Since 2019, AFEP has been strongly advocating for the EU to take concrete actions to tackle carbon leakage and related competitiveness gaps at the expense of EU-based industries.
In the context of the European Green Deal, EDA shares and fully supports the EU’s ambition to take coherent and forceful leadership at European and global level. The dairy industry is committed to play its role within this new set of policy tools to further strengthen our full engagement and support to the efforts made at all levels of the supply chain.
Summary of recommendations by Wacker AG: 1) The Commission should follow up on its recent commitment to strengthen existing carbon leakage instruments (free allocation and indirect cost compensation). As a minimum, current level of support must be guaranteed for the upcoming EU ETS phase 2021-2030.
CONSULTA PÚBLICA SOBRE O ROTEIRO PARA A AVALIAÇÃO DE IMPACTO INICIAL DE UM MECANISMO DE AJUSTE FRONTEIRIÇO DE CARBONO (CBA- CARBON BORDER ADJUSTMENT) - Comentários da CIP Ao adotar o caminho da neutralidade climática, sob orientação do Roteiro Nacional RNC2050 e do Acordo Verde Europeu, as empresas portuguesas têm como objetivos primordiais a sua eficiência em termos materiais e energéticos, para reduzir consumos e…
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
VÍTKOVICE STEEL, a.s. supports the Commission's endeavour in instituting a carbon border adjustment measure to "[fight] climate change by avoiding carbon leakage”. For the steel sector in particular, the final measure needs to do two things: 1. The scope of the measure needs to cover the full steel value chain 2.
ABOUT EUPC European Plastics Converters (EuPC) is the leading EU-level trade association, based in Brussels, representing European plastics converting companies. Plastics converters use plastics raw materials and recycled polymers to manufacture new products, which are purchased preferably in Europe or outside the Single Market.
FEVE Contribution on the Inception Impact Assessment on Carbon Border Adjustment Mechanism. 31th of March 2020 FEVE , The European Container Glass Federation, welcomes the possibility to provide feedback on the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM).
Ajinomoto Animal Nutrition Europe (AANE), subsidiary of the Ajinomoto Group, is the main producer of feed grade amino acids established in the European Union, exclusively by fermentation. Amino acids are the main building block for proteins.
The Federation of Austrian Industries (IV) acknowledges the political relevance of a Carbon Border Adjustment Mechanism (CBAM) as well as the European Commission’s intention to prevent that less-ambitious international partners undermine the EU’s climate ambition.
The Climate Law includes the goal of climate neutrality for the EU by 2050. Reaching this target is likely to involve a significant increase in carbon prices. To avoid a loss of competitiveness for EU industries and higher CO2 emissions in other regions, we support the principle of protecting efficient european industries exposed to unfair international competition through a Carbon Border Adjustment Mechanism…
As the umbrella association of the 16 consumer centres of the German Länder and 26 broad consumer policy associations in Germany, the Verbraucherzentrale Bundesverband e.V. (vzbv — www.vzbv.de) pools the forces for strong consumer protection in Germany and in the European Union. Vzbv is based in Berlin and has an office in Brussels. The Vzbv welcomes the discussion on a carbon border adjustment mechanism.
Filed in German · English published by the European Commission
AIEE a non-profit professional organization, the Italian affiliate of the International Association for Energy Economics – IAEE, is an interdisciplinary forum for the exchange of ideas and experiences among energy experts.
CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), welcomes the initiative to respond to the improvement of the carbon border adjustment mechanisms by the European Commission.
The European Bicycle Manufacturers Association (EBMA) represents the EU Bicycle, Pedal-Assist E-Bike and Bike Components Industry with more than 900 SMEs and 110.000 Workers in 23 of 27 EU Member States. The EU Bicycle, Pedal-Assist E-Bike and Bike Components Industry is a major contributor to the EU’s decarbonization goals and forms one of the EU’s Green Industries.
COMMENTS of the Association UKRMETALURGPROM (Ukraine) concerning the Carbon Border Adjustment Mechanism. Association UKRMETALURGPROM represents the whole Ukrainian steel industry. Ukraine fully shares ambitious climate change agenda of the European Union and is an active participant of the UN Framework Convention on Climate Change.
AVE and its Members highly recognize and support all measures of the European Commission (EC) to be more sustainable and climate friendly, and in seizing methodologies such as this carbon border adjustment mechanism in order to establish some kind of level playing field between EU- and Non-EU-Companies and to prevent carbon leakage.
The attached document is an opinion developed, on the basis of an own initiative, by the Consultative Commission on Industrial Change within the European Economic and Social Committee. Th opinin has been finally adopted by the plenary session of the EESC in July 2019 , and contains clear motivation, recommendation and comcrete proposal of a sistem to implement the border adjustment measures (BAMs) on the basis of…
ThyssenKrupp Steel Europe AG is a subsidiary of thyssenkrupp AG and one of the world’s leading suppliers of carbon steel flat products. With around 27.000 employees we supply high-quality steel products for innovative and demanding applications. With an annual production volume of approximately 12 million metric tons of crude steel, we are Germany’s largest flat steel producer.
Filed in German · English published by the European Commission
KONSULTATIONSANTWORT Europäischer CO2-Grenzausgleichsmechanismus Die Europäische Kommission denkt derzeit darüber nach, ob und inwiefern ein Grenzmechanismus zum Ausgleich von CO2-Belastungen zielführend ist. Es ist noch völlig unklar, wie ein solcher Mechanismus ausgestaltet sein soll und welche Sektoren davon betroffen sind.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Spanish Cement Association (OFICEMEN) welcomes the idea of a carbon border mechanism as a unique opportunity to enable the industry to help deliver the EU’s carbon neutrality objectives and drive deeper CO2 emissions’ cut in the EU and beyond. The European cement industry already faces a strong risk of carbon leakage despite the partial free allocation provided under the EU Emission Trading Scheme (ETS).
Eucolait welcomes the opportunity to comment on this roadmap in view of introducing carbon border adjustment measures, with the ultimate aim of helping to achieve carbon neutrality in the EU by 2050. Eucolait agrees with the overarching goals of the Green Deal and supports the shift towards increasingly sustainable food systems, while at the same time meeting the growing demand for food.
EK appreciates a possibility to deliver views of Finnish businesses regarding a Carbon Border Adjustment Mechanism. The introduction of Carbon Border Adjustment Mechanisms (CBAMs) requires very serious consideration of their costs and benefits.
Iberdrola welcomes the EU initiative to assess the proposal of a Carbon Border Adjustment Mechanism (CBA) to enhance EU climate targets, reduce the risk of carbon leakage and avoid distortions on international trade ensuring that the price of imports reflect accurately their carbon content, preserving World Trade Organization-WTO rules and other international obligations of the EU.
Dear Sir/Madam, The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success. This impact assessment is an important step to have the right design in place.
The Federation of Aluminium Consumers in Europe (FACE) represents interests of EU aluminium downstream (DS) transformers and users. The goals of FACE and the proposed EU CBAM coincide: levelling the playing field for EU industries on the domestic and export markets and preventing escape of EU industrial production to third countries with lower or no CO2 emission costs.
ACV-CSC METEA is the largest national industrial trade union in Belgium. We defend the interests of all workers in the metal and textile sectors, thanks to the daily work of our 10 000 activists and the confidence of our 220 000 members and the valuable contribution of all employees to the organisation. ACV-CSC METEA welcomes the principle of border carbon adjustment.
Filed in French · English published by the European Commission
Please find attached the contribution from EUROFER, the European steel association. It includes the following documents: 1. Paper on border adjustment and carbon leakage measures 2. Legal opinion by law firms Nctm, Luther and GIDE on WTO compatibility aspects of carbon border measures 3.
Copa and Cogeca represent 22 million farmers and their family members as well as 22,000 cooperatives that are dedicated to providing 446 million EU citizens with safe, nutritious, high-quality and affordable food every day. European farmers, forest owners and their cooperatives are the first to feel the impact of climate change.
The European Panel Federation (EPF), warmly welcomes the Impact Assessment of the carbon border adjustment mechanism. Such a mechanism is a fundamental tool for the implementation of an effective climate policy in a globalised economy and to ensure international competitiveness of European industries.
For the DBV agricultural commodities and food products should be included in a carbon border adjustment in order to prevent carbon leakage in EU agriculture, provided there is a practical way to do it. Given the proposed increase of the EU’s climate ambition (also compared to other countries in the world) it is necessary to reflect the mitigation targets in trade policy in order to avoid carbon leakage (and as a…
CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the idea of a carbon border mechanism as a key opportunity to enable the industry to help deliver the EU’s carbon neutrality objectives, and drive deeper CO2 emissions’ cut in the EU and beyond: • The European cement industry already faces a strong risk of carbon leakage despite the partial free allocation provided under the EU Emission Trading…
The enclosed document gives the reactions from the Finnish Technology Industries – which accounts over 50 % of the Finnish exports - to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms. Given the expected potential higher climate ambition for 2030, we recognize that additional and improved carbon leakage provisions may be needed.
The ambitious goal of a carbon-neutral economy by 2050 requires accompanying the financing of massive investments, the emergence of disruptive technologies and the preservation of companies with less ambitious international competition. France and Europe have become aware that their climate policy weakens their champions without reducing global emissions and that it leads to the transfer of emissions across borders.
Filed in French · English published by the European Commission
APPLiA Bulgaria’s Views on the Carbon Border Adjustment Tax In the frame of the EU climate strategy, the European Union will have the challenge of designing policy that will reduce CO2 emissions and encourage greener industry in Europe, while avoiding making European industry less competitive both in the internal market and on the world market.
CBAM is a necessary step for the Commission to take in order to ensure getting close to the Climate Target of the EC Green Deal. Discussions about possible conflicts with WTO rules have run out of steam and, anyway, Climate issues are so critical that they ought to take precedence over trade issues - a further step in world governance, if the present COVID-19 crisis is resolved and the world that comes out of it is…
1. Aims The BA aims at making the EU ETS more effective for climate protection and avoiding or reducing existing and potential competitive disadvantages and carbon leakage. 2. Coverage The BA should apply to imports, not to exports. It imposes a charge equivalent to the EU ETS to imported products or services. 3. Sectors The BA should first only cover one climate-intensive sector.
A WTO-compatible Border Tax Adjustment for the ETS to Finance the EU Budget Abstract: One element of the proposed European Green Deal is a border carbon adjustment mechanism. The introduction of a BCA would allow the EU to phase out current carbon leakage provisions of the ETS and to auction off all emission allowances, thus rendering the ETS a more effective unilateral tool to price and reduce carbon emissions.
[extract] We are pleased that both the Green Deal Communication and the Inception Impact Assessment for the CBAM acknowledge the problem of carbon leakage, and that the Commission is proposing a new measure aimed at tackling it (i.e. the CBAM).
With a number of French trade union leaders and a former MEP, we have founded the BRIDGE, an association that defends the idea of a necessary industrial renewal through the democratisation of economic and social decisions and ecological engineering at European level.
Filed in French · English published by the European Commission
Gas Networks Ireland (GNI), along with its parent company Ervia, welcomes the opportunity to provide feedback on the “EU Green Deal – Carbon Border Adjustment Mechanism.” GNI acknowledges that this mechanism will move towards protecting the competitiveness of the European economy.
EUROALLIAGES calls for a serious multi-dimensional assessment that includes not only energy and climate angles but also fundamental aspects of EU’s trade and single market instruments and goals. EUROALLIAGES recommends the following: 1. Any CBAM system that intends to replace or remove the carbon leakage regime featured by the ETS Directive should be disregarded.
In rolling out the EU climate strategy, the European Union will have the challenge of designing policy that will reduce CO2 emissions and encourage greener industry in Europe,while avoiding making European industry less competitive both in the internal market and on the world market. In avoiding carbon leakage, the EU must also avoid the “leakage” of the strength of European industry.
UPRINAZ welcomes the initiative of the European Commission to achieve a new mechanism to avoid carbon leakage and to put all EU economic actors on an equal footing with their global competitors. Uprigaz noted that there were two weaknesses in the HTA mechanism: If the ETS allows certain industrial sectors to avoid paying a carbon tax in the European Union, the scheme does not protect these industries against…
Filed in French · English published by the European Commission
The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success.
Dear Sir, dear Madam, ICC France is one of the 90 National Committees belonging to the International Chamber of Commerce. Aligning trade and climate policies is one of our core objectives so as to combat climate crisis and to reinvigorate the multilateral trading system. The ICC organised in 2019 a series of consultations on 4 different potential alignment tools including Carbon Border Adjstment measures.
Carbon leakage is a clear and present danger for many Norwegian industries. It should be noted that the risk of carbon leakage is not limited to the threat of relocation of activities but also impinge on daily operations and profitability and most importantly, future investments.
The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success.
The European Industrial Gases Association, EIGA, is pleased to share its views on the Inception Impact Assessment on the Carbon Border Adjustment Mechanism (CBAM). The Green Deal mentions the need to reduce the risk of carbon leakage should differences in the level of ambition of various regions of the World persist.
Amici della Terra Onlus believe that the best way to introduce a non-discriminatory Carbon Tax in the EU would be the proposal developed by Prof. Gerbeti, called "Tax on Added Emissions (ImEA)”. This would not be punitive for European industry and, conversely, it would enhances its characteristics of sustainability.
When the EU: The EU’s climate strategy will be implemented with the challenge of developing a policy that will reduce CO2 emissions and encourage greener industry in Europe, while avoiding making European industry less competitive on both the internal and world markets.
Filed in Swedish · English published by the European Commission
Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. We welcome the opportunity to provide feedback on the “EU Green Deal – Carbon Border Adjustment Mechanism.” GD4S acknowledges that this mechanism will move towards protecting the competitiveness of the European economy.
The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success.
After a long (too) long period when the CO2 price on the European market for emission allowances was structurally below EUR 10/t, the carbon price finally ended in 2019, and the price signal began to produce its effects.
Filed in French · English published by the European Commission
Bankwatch strongly supports a carbon border tax for the electricity sector. The EU is not predicted to be a net importer of electricity in the coming years, but it does import electricity from, and exchange electricity with, countries on its borders such as Bosnia and Herzegovina, Serbia, Ukraine, Belarus and Russia, whose electricity sectors are heavily dependent on coal.
EXTERNAL NOTE Carbon Border adjustment mechanism Our reference / 202003271629SEM Publication date / 27 March 2020 [name removed] Advisor [name removed] Deputy Advisor Competence centres Climate, Energy & Mobility Europe & International sem@vbo-feb [email removed] Summary FEB questions for the impact assessment about the carbon border adjustment mechanism.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
On 4 March 2020, the European Commission published the Inception Impact Assessments “Carbon border adjustment mechanism”. FESI welcomes the possibility to provide comments to it and would like to take this opportunity to present its view on the different options put forward by the European Commission.
The stated aim of the initiative is to tackle asymmetrical climate ambition between the EU and its trade partners which may result in carbon leakage. Carbon leakage is defined in the Inception Impact Assessment (IIA) as the transfer of production and investment to countries with lower climate ambition and/or the replacement of EU products with more carbon intensive ones from outside the EU.
ActionAid has produced a discussion paper which seeks to analyse the possible consequences or benefits for developing countries of a carbon border adjustment (CBA). While we recognise the possible rationale of the CBA from a climate objective perspective, in our discussion paper and in this feedback we focus more on social justice questions that may arise from a CBA, especially in relation to potential impacts on…
27 March 2020 Ministry of Finance Tax and Customs Department Swedish comments on the inception impact assessment of a carbon border adjustment mechanism The Swedish Government appreciates the opportunity to provide comments on the design of a carbon border adjustment mechanism (CBAM), within the framework of the inception impact assessment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Europe is not an island of climate policy, but one of the largest and most integrated markets in the world. As an export-oriented union, Europe is involved in both international trade agreements and the Paris Agreement. Moreover, it is not a question of cementing existing technologies, but of developing new ones.
INTRODUCTION The European Tyre and Rubber Manufacturers’ Association (ETRMA), representing the voice of tyre and rubber goods producers in Europe, and its members are fully committed to contribute at large to the objectives of the Paris Agreement and the Climate-Neutrality objectives set in the European Green Deal.
LafargeHolcim supports the objectives of the Green Deal and is committed to contributing to the achievement of an EU carbon-neutral economy by 2050. Achieving the common objective of transitioning to carbon-neutral construction relies on ensuring the attractiveness of local production, while promoting innovative low-carbon investments and advanced technologies such as carbon capture use and storage, and creating…
1) Instrument: The CBA should use a fixed and steadily rising price. The price per-tonne CO2e should be lower at first (ie €15/t) to avoid an immediate shock but rise automatically every year by a set amount (ie €10/t). This works best paired with a newly-created domestic carbon fee using the same price and charged upstream “at the source” to ensure economy-wide coverage.
Glass for Europe, the trade association of Europe’s flat glass sector, takes note that the European Commission is considering tabling a legislative proposal to introduce a carbon border adjustment mechanism in EU law. Flat glass manufacturing is an energy intensive activity covered under the EU ETS and the flat glass sector is considered at high risk of carbon leakage.
Total welcomes the initiative of the European Commission to propose a carbon border adjustment mechanism. A well-designed mechanism can be a powerful tool to drive GHG emission reductions globally and at the same time avoid carbon leakage.
Ervia is a commercial Irish semi-state company with responsibility for the delivery of gas and water infrastructure and services in Ireland, through Gas Networks Ireland and Irish Water. Gas Networks Ireland develops, operates and maintains the natural gas transmission and distribution networks in Ireland and provides gas transportation services to all gas suppliers and shippers in Ireland.
On behalf of the Institutional Investors Group on Climate Change (IIGCC) - see www.iigcc.org IIGCC's investor members strongly support carbon pricing as a means of sending clear, long-term investment signals to support the transition to a net zero emissions economy. IIGCC has consistently supported greater climate ambition in the EU ETS through its different Phases and reforms.
Various design options might be considered for carbon border adjustment mechanism to enhance the effectiveness of carbon pricing for the transition to climate neutrality. As a group of academics with an interdisciplinary background, including law and economics, we have analysed three main models that could lead to the introduction of a carbon border adjustment mechanism or alternative measures.
Taking care of competitiveness and avoiding emissions to slip outside of Europe are relevant concerns. Carbon leakage takes place also in the electricity sector, for example between Finland and Russia, as imported electricity carries no cost of carbon. One option is to introduce a Carbon Border Adjustment to place a carbon price also on imported products.
Risk for carbon leakage to be addressed in the context of higher climate ambition Fortum as a major European utility recognises the need to address the increasing carbon leakage risk for the European industries in the context of higher climate ambition and supports the Commission’s initiative to investigate measures in mitigating carbon leakage and establishing a carbon border adjustment (CBA) mechanism in the EU.
The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success.
Dear Sirs, Following more than ten years’ experience as a company focusing on climate mitigation policies and consultancy, we strongly support that the measure shall be an extension of the EU ETS to imports. we have detailed our opinion in the attached document. thank you
This proposal is essential. I want to comment as member of the Roman Catholic Jesuit Order and coordinator of the international research and advocacy project on Tax Justice & Poverty . Given the crisis of multilateralism, the EU as prominent global player needs to be pacemaker and standard-setter in the called-for socio-economic transformation called for by scientific facts and ethical reflection.
Carbon Border Adjustment Mechanism Carbon leakage is a very important issue; we have already seen a move of energy intensive and GHG emissions intensive technologies to the regions with less strict control of emissions.
the carbon border mechanism affects communities in and outside EU. this communities mainly are emigrants that potentially have effective leverage to realise the carbon border mechanisms.they live on both sides of EU border in reality. however they are not aware of such mechanisms due to less Integration in EU.
Making an EU Carbon Border Tax easier with a Carbon Club A border tax must be built on the ETS; that goes for the level of the levy and for use of a possible link with ETS and CO2 markets in other countries. In the preparation of a carbon border tax, in my opinion, the following 6 principles should also apply. 1.
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