Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)

Nemo Link Limited operates the 1000MW HVDC electricity interconnector between GB and Belgium. Please find attached the joint response from Nemo Link and other EU and GB Transmission System Operators including National Grid, Energinet, ElecLink, NeuConnect and BritNed.

Companhia Brasileira de Alumínio (CBA) appreciates the opportunity to contribute to this Public Consultation and reinforces its commitment to the climate agenda and to the development of mechanisms that promote fair conditions for international competition, consistent with the principles of transparency, comparability, and respect for national specificities.

We welcome the opportunity to provide our views to the European Commission consultation on the draft Implementing Act (IA) on carbon prices paid in third countries under the EU Carbon Border Adjustment Mechanism (CBAM).

While Fertilizers Europe supports equal treatment and level playing field for EU producers and foreign exporters of CBAM goods alike, we consider this proposal premature in some aspects. For reasons set out in the attached consultation response, Fertilizers Europe calls on the European Commission to delay adoption of provisions on carbon credits and offsets until EU rules for EU installations are adopted, introduce…

By pricing embedded carbon at the EU border, CBAM gives third-country governments a strong incentive to build domestic carbon pricing systems rather than cede revenue to the EU. It also operates as a carbon pricing mechanism with a legal requirement to impose on imports a cost equivalent to that borne by EU producers under the ETS, an equivalence that depends on the carbon price credited against CBAM liability being…

The Government of Argentina would like to provide feedback with regard to the following aspects: 1. Nature of the measure: Industrial policy and its relationship with the rules of the World Trade Organization (WTO). 2. "Carbon Leakage" and its accounting. 3. Methodology and Regulatory Sovereignty. 4. Carbon as a Tradable Good and the Inconsistency of Imputing External Reference Prices. 5.

Article 9 of the EU Carbon Border Adjustment Mechanism (CBAM) Regulation allows importers to deduct carbon prices effectively paid in a country of origin from their CBAM certificate obligation. How that deduction is implemented will shape not only the distribution of compliance costs and revenues, but also the CBAMs broader ability to catalyze carbon pricing abroad.

We are a Serbian civil society organisation advocating for decarbonisation of Serbias energy sector, alignment with the EU climate acquis and a just transition away from coal. We support the principle that CBAM should avoid double charging where a carbon price has genuinely been paid in a third country.

The National Confederation of Industry (CNI) is the representative body of the Brazilian industrial sector and, as an institution, wishes to put forward points of interest and attention after analysing the documents submitted to the public consultation. Comments are attached in the document

Filed in Portuguese · English published by the European Commission

The International Chamber of Commerce (ICC), the institutional representative of 45 million companies of all sizes and sectors across more than 170 countries, welcomes the opportunity to contribute to the public consultation on the Draft Implementing Regulation under Regulation (EU) 2023/956 concerning the recognition of carbon prices paid in third countries under the Carbon Border Adjustment Mechanism (CBAM)), and…

Sandbag welcomes the opportunity to contribute to the public consultation on the European Commissions proposed implementing regulation (IR), under the CBAM regulation, on the carbon price paid in third countries.

The Climate Action Reserve is an international carbon crediting standard recognized for integrity and with roots in compliance markets. We support the publication of the draft implementing regulation on the carbon price paid in third countries as an important step towards the implementation of CBAM, an innovative approach that is raising global climate ambitions.

The main objective of the Brazilian Biogas and Biomethane Association (ABiogás), which brings together more than 120 companies in the biogas and biomethane value chain, is to work towards the integration, consolidation and sustainability of these strategic resources in the Brazilian energy mix.

Filed in Portuguese · English published by the European Commission

Please find attached our major concerns with the current draft. More time is needed with real-world case studies to be presented by the EU on how the major EU trading partners would be affected. Also, there are mistakes in the draft, which show this whole topic needs more time to be done properly

1. Introduction The Brazilian Chemical Industry Association (ABIQUIM) submits its contribution to the public consultation on the CBAM implementing regulation, focusing on: Conversion of carbon prices paid in third countries; Reduction of CBAM certificates; Proof of carbon price payment; Independent verification requirements.

1. About Trafigura Trafigura is a leading global commodity trading and logistics company supplying metals, minerals, oil, petroleum products, gas, and power to the EU. The Group manages a diverse European asset portfolio, including Nyrstars zinc and lead smelters (France, Germany, Netherlands, Belgium), with refining, storage, biofuels, and renewable energy businesses.

The Canadian Steel Producers Association (CSPA) respectfully requests that the European Commission consider the following key refinements to the proposed implementing regulation: 1. Verification Feasibility and Proportionality Ensure that verification requirements for carbon prices paid remain proportionate, administrable, and feasible given the limited global pool of auditors with combined expertise in emissions…

Ternium (a Latin American steel producer) sends its concerns and commments about the draft regulation rules for converting into a corresponding number of carbon border adjustment mechanism certificates the carbon price paid in a third country for declared embedded emissions, taking into account any form of compensation available in that country resulting in a reduction of the price.

The Global South Carbon Dioxide Removal (GS CDR) Coalition welcomes the opportunity to respond to the draft implementing regulation on the carbon price effectively paid in third countries. The GS CDR Coalition is a network of high-integrity carbon removal suppliers from across Africa, Latin America and Asia, working in pathways including biochar, enhanced rock weathering and direct air capture.

The joint feedback from the Secretariat for Carbon Market of the Brazilian Ministry of Finance (SEMC/MF) and the Secretariat for Green Economy, Decarbonization, and Bioindustry of the Brazilian Ministry of Development, Industry, Trade and Services (SEV/MDIC) can be found attached.

We welcome the opportunity to provide feedback on the draft implementing act outlining the rules for accounting for the carbon price paid in third countries under CBAM. This act is instrumental to the well-functioning and integrity of the EU CBAM, and by extent also the EU ETS due to the interconnection between both policies.

Tata Steel Nederland (TSN) welcomes the opportunity to provide feedback in this consultation. TSN fully supports the eurofer position on this topic. This act is of fundamental importance for the environmental integrity and effectiveness of the CBAM, as it directly determines how carbon costs borne outside the EU will reduce the number of CBAM certificates to be surrendered.

Contribution OF ABRAFE TO THE CBAM PUBLIC CONSULTATION Revision OF default emission VALUES APPLICABLE TO Brazilian Ferroalloys June 2026 ABOUT ABRAFE AND GENERAL Comments The Brazilian Association of Ferroalloy and Silicon Metal Producers (ABRAFE) represent the leading producers operating in Brazil. ABRAFE supports the EU’s objectives in addressing climate change and preventing carbon leakage.

Filed in Portuguese · English published by the European Commission

Singapore is committed to being a constructive partner in supporting EU CBAM implementation in a business-conducive manner. In the attached document, Singapore has provided feedback on the following areas: (a) recognition and treatment of international carbon credits in CBAM levy deductions; (b) clarification on 5% materiality threshold; (c) proposed approach to facilitate emissions attribution and reporting; (d)…

Please find enclosed company comments on the treatment of carbon prices paid in a third country under CBAM. The proposed amendments address the definition of carbon price mechanism in Article 2(3), the treatment of rebates and compensation under Article 8(2), and the related provisions of Annex I concerning carbon credits, compliance options, and supporting evidence.

Energy UK welcomes the draft implementing regulation on carbon price recognition under CBAM and supports the EU's climate ambition. However, the draft contains gaps that are particularly acute for electricity imports, risking a framework that is simultaneously unworkable for operators and miscalibrated as a carbon leakage prevention tool.

WindEurope welcomes the consultation on this draft Implementing Regulation, which is decisive for the environmental integrity and effectiveness of CBAM. However, the proposal raises concerns for both the integrity and practical implementation of CBAM. While the proposal recognises carbon costs in third countries, aspects of it risk introducing uncertainty, administrative burden, and distortions.

Carbon Market Watch is concerned with the willingness of the European Commission to allow for domestic and international credits to account as carbon price paid in a third country. Not only this represents a discrepancy with the current EU ETS architecture, but sets a dangerous precedent that incentivises the establishment of crediting schemes with no qualitative safeguards. Our feedback is in the document attached.

As a company that restores Nature at a large-scale to high integrity standards all over the world, aDryada welcomes the opportunity to comment on the EU Commissions Carbon Border Adjustment Mechanism (CBAM) draft Implementing Regulation on carbon price paid in a third country. Already the CBAM has led to the development of a multitude of carbon pricing mechanisms in countries around the world.

The International Swaps and Derivatives Association (ISDA) welcomes the opportunity to provide feedback on the European Commissions consultation on the calculation of the carbon price paid in a third country under Article 9 of the CBAM.

Liquid Gas Europe (LGE) represents the distributors of LPG and renewable liquid gases, as well as equipment manufacturers in Europe. LGE supports the objective of ensuring an effective and predictable carbon pricing framework that prevents carbon leakage while preserving fair competition, proportionality and the circular use of long-life industrial assets.

The robustness of CBAM depends on the strict equivalence between the carbon costs borne by EU producers and those applied to imports. The implementing rules on the recognition of carbon price paid in third countries must therefore ensure consistency, transparency and comparability across jurisdictions in order to preserve both environmental integrity and fair competition.

The suggested carbon border adjustment mechanism is a welcome and important effort to create a fairer process when assessing carbon impacts of goods and services. It is often difficult to perform a full accounting of all local, national and global greenhouse gas emissions associated with our actions and consumption.

1. Avoid Double Carbon Payment : Support clear provisions to prevent double carbon payment and agree the recognition of carbon price effectively paid in the third country as a basis for reducing the number of CBAM certificates to be surrendered.

Feedback on the draft Implementing Regulation on the carbon price paid in third countries (Article 9(5) of Regulation (EU) 2023/956) This submission is made on behalf of APERAM SA, a global player in stainless, electrical and specialty steel and recycling, with several production capacities in Europe operating under the EU ETS. We support the CBAM's objective of preventing carbon leakage.

Yara International is Europe's leader in ammonia and fertilizer production as well as the world leader in ammonia trade. The draft Implementing Regulation allows for carbon credits or other emission units purchased under a baseline-and-credit emissions trading system to be considered equivalent to allowances paid under an emissions trading system.

Recommending Recognition of China's Green Power Trading in CBAM Indirect Carbon Emissions Accounting Abstract: China has established a green electricity trading mechanism as the primary measure for greenifying electricity consumption by various types of users.

Subject: Polish Steel Association (HIPH) comments with reference to the draft Implementing Regulation on the carbon price paid in a third country under CBAM The Polish Steel Association (HIPH), representing the Polish steel industry, welcomes the opportunity to provide comments in the context of the consultation on the draft Implementing Regulation laying down rules on the carbon price paid in third countries under…

Key messages: 1. Publish default carbon prices as soon as possible - The Commission should publish the methodology and timeline for default carbon prices as soon as possible, especially for electricity imports that will largely rely on default values.

The Terawatt Times Institute (EU Transparency Register 8269215104555-62) submits this response to the draft implementing regulation on the carbon price paid in third countries. The thirteen jurisdictions documented here are drawn from an ongoing empirical programme now covering thirty-five exporting economies and still expanding, in which the per-origin correction proposed below is being fitted at the algorithmic…

Department of Climate Change and Environment (DCCE), DCCE, would like to offer the following observations and requests for clarification regarding the draft Regulation: 1. Paragraph 9 Emission Factors for Fuel-Based Carbon Pricing Paragraph 9 provides that where a carbon tax, levy, or fee is imposed on fuels used in the production of goods, the corresponding carbon price may be claimed for deduction purposes based…

The Business for CBAM Coalition welcomes the opportunity to provide feedback on the draft implementing act for CBAM carbon price accounting rules, but raises two critical concerns: the eligibility of international carbon credits for CBAM compliance, and the excessive administrative burden and complexity of the proposed mechanism.

Volvo Cars supports the objectives and overall design of the Carbon Border Adjustment Mechanism (CBAM) as a key instrument to prevent carbon leakage and to incentivise the development of robust carbon pricing systems globally. Aligning carbon costs across jurisdictions is essential to ensuring a level playing field and accelerating global decarbonisation.

1. CBAM should priorities verified actual emissions data over default values to improve accuracy and support industrial decarbonization. 2. Default values should be realistic, transparent and reflect actual production conditions. 3. The methodology should recognize proven efficiency improvements and low-carbon energy sourcing, particularly in energy-intensive sectors. 4.

1. Regarding rebates and other forms of compensation：CBAM should recognise carbon costs paid by enterprises for compliance within subnational pilot carbon markets. Further, for fossil fuel-dependent developing countries including China, carbon emissions show a strong linear correlation with energy consumption.

Youth and Environment Europe (YEE) is the largest independent European network of youth environmental organisations, representing over 45 member groups and thousands of young people who advocate for sustainable, just, and science-based policies.

The draft instruments constitute a sound and generally well-balanced legal framework that supports the objectives of CBAM and enhances the credibility of carbon-price recognition. Nevertheless, targeted improvements addressing proportionality, administrative burden, the treatment of international carbon credits, the transparency of default carbon-price determinations, and the accessibility of the accreditation…

Recommendation 1: Directly recognize China's national carbon market compliance certificates to eliminate redundant secondary verification. The European Commission should establish a direct mutual recognition arrangement for the "List of Chinas National Carbon Market Compliance Certificates." We urge the Commission to explicitly include the following official Chinese documents into the scope of directly accepted…

BeZero Carbon welcomes the EU Commission's introduction of the Carbon Border Adjustment Mechanism (CBAM) and its recognition that domestic and international carbon credits under third-country pricing mechanisms can be used to meet CBAM obligations.

The Nature Conservancy welcomes the opportunity to feedback on the CBAM Draft Implementing Regulation regarding Carbon Prices Paid in a Third Country. In this submission, we address the following issues in the Commissions Draft Regulation and sets out its corresponding recommendations: How can the European Commission ensure the environmental integrity of both domestic and international carbon credits recognized…

Ørsted welcomes the opportunity to provide feedback on the draft Implementing Regulation on the carbon price paid in third countries under CBAM. Ørsted welcomes the intent of article 6(2), to evaluate carbon prices at the same granularity, in this case yearly.

On behalf of the Ministry of Environment, Taiwan, we welcome the opportunity to share our feedback and contribute toward a robust and effective EU CBAM. In our view, it is vital that the future regulatory framework balance environmental integrity with predictability, proportionality, and compliance with international trade obligations.

Dear Sirs and Madams, We support the proposal from Gerber Steel attached as a PDF and call for significant simplifications to the Commission's proposal regarding the deduction of CO2 emissions already paid for in third countries and for importing small and medium-sized enterprises. Thank you very much.

IETA welcomes the opportunity to provide feedback on the draft Implementing Act on the carbon price paid in third countries under CBAM. IETA's response focuses on the need for timely implementation guidance, including on default carbon price values, the treatment of credits used under third-country compliance systems, and reporting and verification requirements.

SUMMARY: Bellona has long supported the CBAM as a mechanism that both enables the phase-out of free allocation under the EU ETS while preventing carbon leakage and encourages decarbonisation and carbon pricing beyond the EU. Bellona supports the distinction made in the draft Regulation between the carbon price and the carbon price effectively paid.

Abu Qir Fertilizers Co., Egypt : We highly appreciate the opportunity to submit our views based on the specific areas outlined by the Commission. We respectfully submit the following recommendations to ensure that the implementation of the Carbon Border Adjustment Mechanism (CBAM) remains fair, proportionate, and effective while preserving the competitiveness of efficient producers outside the European Union. 1.

We welcome the recognition of expenditure on both international and domestic carbon credits as an equivalent carbon price. This ensures that carbon prices already paid by installations are recognised and maintains coherence with the realities of carbon pricing mechanisms globally.

Drax welcomes CBAMs objective of preventing carbon leakage, whilst also retaining the integrity of the EU ETS and avoiding double charging of carbon costs on the same emissions. We further welcome the recognition of carbon credits as equivalent to emission allowances, subject to these being already accepted as a compliance option for a local ETS or carbon tax.

DNV welcomes the opportunity to provide input on the draft implementing regulation concerning the recognition of carbon prices paid in third countries under the Carbon Border Adjustment Mechanism (CBAM). The proposal represents an important step towards ensuring that carbon costs borne outside the EU are appropriately accounted for, while maintaining the environmental integrity of CBAM.

Iberdrola welcomes this proposal as a means to enhance transparency and visibility in the implementation of the CBAM. This will support European industry in investing in its transformation, enabling it to reduce dependence on fossil fuels sourced from third countries, which are subject to volatile prices and geopolitical uncertainties that undermine competitiveness.

Australias Department of Climate Change, Energy, the Environment and Water (DCCEEW) welcomes the opportunity to provide feedback on the EU CBAM rules for the application of Regulation (EU) 2023/956. The submission discusses how the provisions in the draft implementing regulation interact with the Safeguard Mechanism.

Proposal 1: Respect the national sovereignty and right of self-determination of third parties in rules governing the use of carbon credits for CBAM deductions Proposal 2: Expand the scope of Article 6 ITMOs for CBAM deductions to cover credits used for fulfilling NDCs Proposal 3: Publish full data and methodologies for default carbon prices and conduct prior consultations with competent authorities Proposal 4: Add a…

Bioenergy Europe supports the EU climate targets for industrial decarbonisation, preventing carbon leakage, and ensuring a level playing field throughout the value chain for the whole European industry. However, as CBAM is implemented and carbon-related costs are reflected in materials such as steel and aluminium, it is important to review potential unintended impacts on the competitiveness of downstream…

EDF is an international non-governmental organization with expertise in carbon markets, climate finance, and international climate policy, including crediting mechanisms under the Paris Agreement. EDF supports the objective of the IR, with the following observations: 1) The IR unduly constrains the set of third-country carbon pricing measures that are eligible for recognition, potentially exposing the EU to a legal…

While it is understood that the proposed implementing regulation aims to ensure that a carbon price is not paid twice on the same emissions, the implementing regulation in its current form imposes severe implications on the developing countries, and is accordingly undermining the principles of equity and Common But Differentiated Responsibilities (CBDR) under the UNFCCC and Paris Agreement.

How does the EU ensure that the information provided by the third country supplier is correct? Indeed, the suppliers’ tasks are crucial to the CBAM cost. Will there be a requirement from the EU for suppliers in the EU to disclose the impact/cost of the CBAM on the price of the product?

Filed in Swedish · English published by the European Commission

This initiative will set out a set of rules to convert the price paid in a third country for the declared embedded emissions into a corresponding number of CO2 border adjustment mechanism certificates, taking into account any form of compensation available in that country that results in a price reduction.

Filed in Italian · English published by the European Commission

1. The draft regulation restricts the recognition of carbon price only to binding carbon pricing mechanisms i.e. where lies mandatory/compliance obligations. We therefore request to specifically publish country wise exhaustive list of carbon pricing instruments eligible for deduction. 2. The methodology for calculation and attribution of carbon cost appears to be complex with no calculation examples in place.

Please find attached a position paper prepared by POSCO on the "EU CBAM Stakeholder Consultation on Draft Commission Implementing Regulation on the carbon price paid in a third country into a corresponding reduction of that carbon price, the qualifications of the independent person and conditions to ascertain its independence and qualifications".

UNICA, the Brazilian Sugarcane and Bioenergy Industry Association, is pleased to submit its contribution to the European Commissions public consultation on the draft Implementing Regulation concerning the recognition of carbon prices paid in third countries under the Carbon Border Adjustment Mechanism (CBAM).

We are grateful to give our feedback to the European Commission, attached is our revised consultation response with our recommendations to the development of a fair, equitable and high integrity CBAM regarding draft (Ref. Ares(2026)4841230 13/05/2026).

Sir / Madam, MSCI would like to thank the European Commission for providing us an opportunity to respond to the consultation on draft act: Carbon border adjustment mechanism (CBAM) - carbon price paid in a third country. Please find attached our response to the Consultation. If there are any clarifications required on our submission, you may please reach out to me. We would be happy to discuss.

CAP-A is an African think-and-do tank working at the intersection of climate policy, green industrialisation, carbon markets, and development finance. We welcome the draft regulation and broadly support its technical architecture.

IFIEC answer to the EU consultation CBAM implementing regulation carbon price paid in third countries Ensure environmental integrity and a level playing field The robustness of the CBAM depends on the strict equivalence between the carbon costs borne by EU producers and those applied to imports.

ESPA supports the objective of avoiding double carbon pricing on the same embedded emissions. Ensuring that genuine, mandatory and effectively paid carbon prices are recognised is essential to CBAMs environmental credibility and its proportionality as a climate measure.

The principle that any recognition of carbon costs paid outside the EU should remain fully aligned with the rules and principles of the EU Emissions Trading System (EU ETS). Any divergence from ETS rules risks undermining the environmental integrity of the CBAM and weakening the carbon leakage protection provided to European industry. Please see attached

We welcome the European Union's continued efforts to operationalize the Carbon Border Adjustment Mechanism (CBAM) and the present consultation on the recognition of carbon prices paid in third countries. The initiative represents an important step toward promoting global decarbonization, preventing carbon leakage, and strengthening international climate ambition in line with the objectives of the Paris Agreement.

CLEPA welcomes the Commissions proposal to establish a framework for the recognition of carbon prices already paid in third countries. Ensuring that the same emissions are not subject to carbon pricing twice is essential to preserve the fairness, credibility and effectiveness of the CBAM framework.

We are quite skeptical about recognizing carbon costs outside the EU due to the absolute disparity between the functioning of carbon charging in the EU and outside the EU. Even if a system outside the EU exists, we are unable to assess its relevance in a wider perspective.

European Metals represents European producers of non-ferrous metals (NFM), such as aluminium, copper, lithium, nickel, zinc, silicon, as well as ferroalloys and other metals that are essential to the green and digital transitions. Amid high energy and carbon costs, the need for a framework that enables the European industry to survive and continue growing has become even more urgent.

What process will the European Commission use to recognise and validate South Africa's carbon tax system for the purpose of deducting carbon prices already paid under CBAM? Will recognition occur at the CBAM Registry level, or must each installation independently demonstrate that carbon prices have already been paid?

Hi, Please find comments from FerroAlloys South Africa. We have a number of concerns and cannot find a proper place to load them all therefore using this portal to submit. Is there a South African representative we can discuss our concerns with please?

Developing CBAM benchmarks derived from EU ETS benchmarks : A request for Review of Secondary Aluminium Benchmark Treatment under CBAM. We welcome the European Commission's efforts to establish benchmark values that support the objectives of CBAM while encouraging decarbonisation and fair competition across global aluminium value chains.

CBAM is a heavy burden and administrative burden for me as an importer, and costly to no climate benefit at all! All that happens is to increase inflation as end users will have to pay a higher price for my products. CBAM is a very poor use of business resources and has no climate impact, my proposal is to scrap the entire reform and return to free world trade as it was before.

Filed in Swedish · English published by the European Commission

We welcome the Commissions effort to improve legal certainty regarding recognition of carbon prices paid in third countries. We support the exclusion of purely voluntary corporate offsets in the system in order preserve the decarbonisation objectives of the CBAM.

Executive summary (detailed response in the attachment) 1. Clarification Needed on the Treatment of Fuel Based Carbon Taxes The proposed Annex 3.3.3 outlines a fuel based carbon tax algorithm which requires an emission factor for the fuel.

1.Taiwan's carbon fee mechanism has its own unique design. Businesses commit to carbon reduction targets with the government, and only when they actually invest in carbon reduction efforts and achieve their targets can they obtain a preferential carbon fee rate compared to the standard rate.

2.5. Use of Default Carbon Prices for Precursors and Indirect Emissions Article 4 of Chapter II of the Draft Regulation allows declarants to use default carbon prices established by the EC for precursors produced outside the installation and for indirect emissions.

The Polish Steel Association (HIPH), representing the Polish steel industry, welcomes the opportunity to provide comments in the context of the consultation on the draft Implementing Regulation laying down rules on the carbon price paid in third countries under the Carbon Border Adjustment Mechanism (CBAM).

2. Specific Comments 2.1. Simplification of Documentation Requirements and Independent Verification Costs Article 9 of Chapter III of the Draft Regulation requires companies to provide various supporting documents and obtain validation from independent verification bodies accredited in accordance with EU standards.

1. General Comments Viet Nam proposes that the European Commission (EC) adopt a more flexible and comprehensive approach to the recognition of third-country carbon pricing mechanisms, including policy instruments being implemented under the green transition roadmaps of developing economies.

Dear Members of the European Commission, We, Taiwan Steel and Iron Industries Association, hereby submit our views and requests for clarification in response to the public consultation on the draft implementing regulation for the EU Carbon border adjustment mechanism (CBAM) carbon price paid in a third country. Please see the attachment.

The Ministry of Economic Affairs of Taiwan welcomes the European Commission's efforts to establish a framework for recognising carbon prices paid in third countries under the Carbon Border Adjustment Mechanism (CBAM).

1.Taiwan's carbon fee mechanism has its own unique design. Businesses commit to carbon reduction targets with the government, and only when they actually invest in carbon reduction measures and achieve their targets can they obtain a preferential carbon fee rate compared to the standard rate.

1.Taiwan's carbon fee mechanism has its own unique design. Businesses commit to carbon reduction targets with the government, and only when they actually invest in carbon reduction measures and achieve their targets can they obtain a preferential carbon fee rate compared to the standard rate.

Fecc welcomes the Commissions draft Implementing Regulation on recognising carbon prices paid in third countries under CBAM and supports its objective of avoiding double carbon costs while maintaining a level playing field.

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

CarbonChain, a carbon accounting and CBAM compliance platform working across multi-tier steel, fertiliser and aluminium chains, welcomes the draft and its core design (actual-values gate, recital 5; verification link, recital 25; standard templates; default-price fallback). Our recommendations focus on workability and accuracy. 1. Recognise third-country carbon border adjustments.

We welcome the opportunity to provide feedback on the draft implementing legislation for the Carbon Border Adjustment Mechanism (CBAM), particularly concerning the recognition of carbon prices paid in third countries.

For CBAM to support rather than undermine European industrial competitiveness, the carbon price recognised in third countries must be assessed according to criteria that are genuinely comparable to those faced by producers under the EU Emissions Trading System (EU ETS). This also means removing risks of circumvention that exist in the current draft implementing act. In particular, Hydro calls for the following: 1.

Gerber Steel GmbH is a medium-sized importer and distributor of stainless steel and aluminium products and, as an authorised CBAM declarant, is directly and vitally affected. We share the stated aim of avoiding double CO2 pricing - yet the current draft falls completely short of this objective.

The Call for Contributions and the Implementation Regulation provide that embedded indirect emissions will be calculated on the basis of standard emission factors derived from fossil sources, using actual values conditional to cumulative requirements.

Filed in Portuguese · English published by the European Commission

Please find enclosed TIC Council's feedback. While maintaining the core elements of the proposal, TIC Council would like to propose the following improvements to the draft act: 1. Clarify the term independent person; 2. Need for guidance for the international carbon markets recognition; 3. Recognition of verification evidence when coming from an accredited body following international standards; 4.

Please see the attached document for Centrica's detailed response. Overall, Centrica welcomes the draft regulation on recognising carbon prices in third countries as a step forward, despite maintaining that including electricity in CBAM is inappropriate. Alignment of annual average carbon prices and CBAM certificate pricing improves methodological consistency.

European Accreditation (EA) appreciates the constructive, fruitful and trustful cooperation with the European Commission on the accreditation of verifiers under the EU Carbon Border Adjustment Mechanism (CBAM), especially regarding embedded emissions. This cooperation demonstrates the value of a well-defined accreditation framework for activities that fall within the scope of conformity assessment.

UK Steel welcomes the opportunity to comment on the draft implementing legislation for the EU CBAM, focusing on the treatment of carbon prices paid in third countries. We support the objectives of the EU CBAM to prevent carbon leakage, maintain a level playing field and encourage global decarbonisation.

UGI International fully supports the environmental objective of the CBAM and the equalisation of the carbon price between European production and imports. Our contribution covers three points on which we believe the final period methodology needs to be clarified and made more operational: Calculation of direct embedded emissions: substantially simplify the collection of actual data from third-party suppliers, in…

Filed in French · English published by the European Commission

In an environment of increasing exchange rate volatility and disparity in global climate ambition, the recognition of payment at source cannot be an automatic or purely accounting process. It requires a robust legal architecture that guarantees the economic substance of what is paid, the traceability of evidence and material equivalence with the EU Emissions Trading System.

Filed in Spanish · English published by the European Commission

We support consolidating carbon-price certification with emissions verification under EN ISO/IEC 17029:2019, and we propose no new actor and no change to the independent person's role, accreditation, liability, or assurance threshold.

WE Soda welcomes the European Commissions draft implementing act specifying how a carbon price already paid in a third country can be deducted from the CBAM obligation. We particularly welcome the establishment of a transparent conversion methodology, detailed evidence requirements, and clear qualification and independence rules for third-party certifiers.

We wish to draw attention to the inappropriate practice of calculating CO certificates in the case of imports of used racks. Used racks are durable products that can last for decades. When used racks are imported into the European Union, these products are often already used both in Europe and in third countries and can be transported several times between different markets.

Filed in Lithuanian · English published by the European Commission

U. S. Steel Košice, s.r.o., shares the concerns expressed in the attached position paper, regarding the draft Implementing Regulation on the carbon price paid in third countries under CBAM. The submission highlights that any recognition of foreign carbon costs must remain fully aligned with EU ETS principles to preserve CBAMs integrity and ensure a level playing field.

Regarding the proposed 5 % tolerance for systematic differences between emissions covered by third-country carbon pricing systems and CBAM boundaries, the current wording lacks clarity concerning its practical application (Recital 7; Annex I, Section 4.2). It remains unclear whether this flexibility would favour or disadvantage non-EU installations compared to EU ETS installations.

We basically welcome the proposal by the EC but need to stress that loopholes of the CBAM need to be taken into account and closed. Such loopholes are the recognition of carbon taxes and levies in third countries, which may only be taken into account as far as those are equivalent with the EU ETS, and the utilization of revenues.

Vitol welcomes the opportunity to comment on the draft Implementing Regulation laying down rules for the determination of the carbon price effectively paid in third countries under the definitive phase of the Carbon Border Adjustment Mechanism (CBAM).

The Business Association of Gipuzkoa, ADEGI, in representation of the enterprises which operates in the region of Gipuzkoa, welcomes the opportunity to give feedback on the initiative which aims to assess the suitability of the carbon price paid in a third country under the Carbon Border Adjustment Mechanism (CBAM).

Proposed amendments and recommendations regarding the recognition of accreditations issued by third-country accreditation bodies under the CBAM framework In order to ensure proportionality, legal certainty, international consistency, and to avoid unnecessary duplication of accreditation procedures, it is recommended that the Implementing Regulation explicitly provide for the recognition of accreditations issued by…

Stegra fully supports the objective of CBAM and recognizes that it, together with the phase-out of free allocation in EU ETS, is one of the most important prerequisites to decarbonize the industry in EU while also incentivizing decarbonization outside EU. The CBAM Regulation allows for a deduction of the carbon cost if a carbon price has been paid in a third country.

This consultation is a crucial opportunity to ensure that the needs and concerns of stakeholders are integrated into the implementing regulations under Articles 7, 9 and 31 of the CBAM Regulation. Below is a synthesis of key considerations and observations, structured along the four requested dimensions. 1.

To ensure a level playing field for European producers, it is essential that a very cautious and conservative approach is adopted in recognising the carbon price in the country of origin. When crediting emissions trading in third countries, the local CO2 price is not a sufficient indicator to assess the real CO2 cost borne by the importers.

The UK and EU share comparable climate neutrality commitments, including legally binding net-zero targets by 2050. Both the UK and EU have Emissions Trading Systems (ETS) that are broadly aligned, and a political agreement reached on 19 May 2025 showing strong commitment linking these schemes. However, the current CBAM framework does not account for this convergence.

(i) Accurately and consistently recognizing third-country CO2 prices remains a key CBAM challenge. To avoid double-counting and uphold environmental integrity, the EU must establish clear, internationally coordinated rules, including formal verification and data-sharing agreements with carbon-pricing third countries, thereby fostering global CO2 pricing alignment.

Article 9 of the CBAM Regulation stipulates that CBAM declarants may claim a reduction in the number of CBAM certificates to be surrendered in order to take into account the carbon price paid in the country of origin. The reduction may be claimed only if the carbon price has been effectively paid in the country of origin.

We ask the European Commission to: 1) Provide clarity on the carbon prices effectively paid in other countries before January 2026; 2) Apply CBAM discount to all electricity traded in a country with an existing carbon pricing mechanism; 3) Recognise complementary third countries carbon pricing mechanisms

This document presents the comments of the Brazilian Aluminium Association (ABAL) on the European Commissions Public Consultation for Preparing an Implementing Regulation on rules for converting into a corresponding number of carbon border adjustment mechanism certificates the carbon price paid in a third country for declared embedded emissions.

To ensure a level playing field for European producers, it is essential that a very cautious and conservative approach is adopted in recognizing the carbon price effectively paid in third countries . When crediting emissions trading in third countries, the local CO2 price is not a sufficient indicator to assess the real CO2 cost borne by the third country producers.

The Würth Group welcomes the Commission’s objective of establishing, through this implementing act, clear rules for taking into account a carbon price paid in third countries. This is an important step to avoid double charging and ensure a level playing field for European companies. At the same time, we would like to draw attention to the significant practical challenges arising from implementation.

Filed in German · English published by the European Commission

CERTAINTY IS NEEDED BEFORE 2026 ON HOW CARBON PRICES EFFECTIVELY PAID IN OTHER COUNTRIES BE CONSIDERED - PARTICULARLY FOR ELECTRICITY Orsted would like to thank for the opportunity to provide input to this important part of the CBAM regulation. It is very positive that CBAM will take into account carbon prices effectively paid in other countries, cf. article 9.3a in the proposed regulation 2025/0039.

EMSTEEL supports a clear, auditable deduction for carbon prices in the country of origin, including proportional credits where domestic pricing covers only part of embedded emissions. To ensure consistency, apply strong anti-double-counting safeguards and standardized CBAM registry templates.

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

Carbon price paid in third countries. A fair and detailed view is needed. UNESID supports the principle that CBAM should recognise carbon prices already paid abroad, but this must be applied with extreme caution. Our main concerns are: 1. Only net, effective carbon costs. Recognition should be limited to explicit and verifiable CO prices that apply equally to all domestic producers in the exporting country.

Thank you for the opportunity to express our opinion on the CBAM. There are multiple forms of carbon pricing outside the EU, including carbon taxes, emissions trading systems, and carbon credit schemes, with system designs differing by country. Non-EU manufacturers already operate while paying these carbon charges.

To ensure a level playing field for European producers, it is essential that a very cautious and conservative approach was adopted in recognizing the carbon price in the country of origin. When crediting emissions trading in third countries, the local CO2 price is not a sufficient indicator to assess the real CO2 cost bare by the importers.

Previous work by ERCST on Crediting Carbon Prices under the CBAM (see link: https://ercst.org/crediting-carbon-prices-under-the-cbam/) has laid important groundwork in exploring how carbon pricing and crediting might interact under the Carbon Border Adjustment Mechanism. However, in light of recent developments, two key points merit further discussion: carbon credits and compensation mechanisms.

The European Automobile Manufacturers Association, ACEA, unites Europes 16 major car, truck, van and bus makers. ACEA members are users and importers of CBAM goods that they use in the building of motor vehicles in Europe. Please find our comments regarding the current consultation in the attached file.

Técnicas Reunidas (hereinafter TR) is a global leader in engineering and construction, specialising in the design and execution of complex industrial facilities. Headquartered in Madrid, which serves as its Operational Excellence Centre, the company operates engineering hubs in Spain, India, Turkey, Saudi Arabia, Chile, and the United Arab Emirates, employing more than 12,000 professionals.

Response to the European Commission Call for Evidence on the carbon price paid in a third country. The European Advanced Carbon and Graphite Materials Association (ECGA) welcomes the Commission's efforts to clarify the methodology underpinning the Carbon Border Adjustment Mechanism (CBAM).

IETA welcomes the opportunity to provide feedback on the European Commissions Call for Evidence on the CBAM implementing act on carbon price paid in a third country. IETA reiterates its strong support for the EUs climate objectives and acknowledges an effective CBAM as a tool to address carbon leakage while incentivising global carbon pricing.

Nemo Link Limited operates the 1000MW HVDC electricity interconnector between GB and Belgium. Please find attached the joint response from Nemo Link and other EU and GB Transmission System Operators including RTE, Elia, Energinet, National Grid Interconnectors, BritNed, ElecLink, GreenLink and NESO.

Thanking you for the opportunity to submit comments, Grupa Azoty hereby submits its proposals. Our most important request is to maintain the allocation of free allowances until the effectiveness of the CBAM mechanism has been fully verified in practice.

We welcome the opportunity to provide our views to the European Commission (EC) call for evidence on the Carbon Border Adjustment Mechanism (CBAM) provisions on the carbon price paid in a third country. The current EU CBAM legislation will lead to many unintended and negative consequences for electricity trade, notably for trading electricity between the EU and the UK.

To whom it may concern, NESO previously responded to the Call for Evidence on Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention and rules on electricity emissions. As part of that submission, we noted the issue of recognition of carbon price paid in the UK on electricity. We now respond jointly with EU and GB TSOs on the matter of carbon price paid in a third country.

You will find enclosed the comments submitted on behalf of HBIS GROUP Serbia Iron & Steel llc, Belgrade to the public consultation on the CBAM implementation: rules on the methodology for calculating emissions embedded in CBAM goods; rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation; rules on the deduction of the carbon price paid in a third country

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

EDF group welcomes the opportunity to provide a feedback on the carbon price paid in a third country. EDF groups main concern relates to how electricity is treated under the current framework. Due to its unique characteristics, an effective implementation of the Carbon Border Adjustment Mechanism (CBAM) for the electricity sector poses challenges.

Novelis, the global aluminium recycling and rolling company, welcomes the opportunity to answer to the consultation of the EU Commission on CBAM on emission methodology, free allocation adjustment and carbon price paid in third countries. Please find it enclosed.

RWE welcomes the opportunity to provide feedback on the Commissions call for evidence regarding the implementing act on carbon price paid in a third country, as foreseen under Article 9 of the CBAM Regulation. Clear rules on the recognition of third-country carbon pricing are critical to ensuring the effectiveness, fairness and credibility of the EU CBAM, and avoiding unnecessary administrative burden.

Bellona Europa calls for the CBAM to recognise the carbon price paid in countries of origin only when it has been effectively paid, without any form of rebates or discounts nor offsets of any form. To achieve meaningful climate impact, any carbon pricing, whether ETS or carbon tax, must cover all emissions directly, disaggregated from any potential offsets or reductions elsewhere in the system.

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

The Ministry of Agriculture and Environment of the Government of Mozambique seeks to partner with the European Union to achieve shared climate and development objectives under the Carbon Border Adjustment Mechanism (CBAM). In Mozambique, our only heavy industry that is exported to the EU at meaningful scale is primary aluminum, which is produced at our sole smelter, Mozal.

Singapore implements a carbon tax regime, and would like to propose how third country carbon pricing could be accounted for under a carbon tax regime. We have ongoing work with consultants examining how to factor our carbon tax into final CBAM levy calculation, to minimise exposure to double taxation on Singapore goods exported to the EU.

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

For simplicity and fairness with EU ETS participants, the carbon price paid in a third country should be based on an explicit carbon price. Carbon markets are complex systems with bankable carbon credits, free allowances, compliance offsets, auctions, secondary markets, reserve prices, etc. The same is true for the EU-ETS and finding the actual price paid by a facility might be impossible to achieve.

CMC Poland supports The Polish Steel Association and EUROFERs position regarding the carbon price deduction mechanism under CBAM. To ensure fairness and environmental integrity, only effective, explicit and net carbon costs paid in the country of origin should be recognised.

With regard to the implementation of the act on carbon price paid in a third country, the FRA wishes to emphasize that: Egypt has established a Regulated Voluntary Carbon Market (RVCM), overseen by the FRA. Credits issued and traded within this system are financial instruments, subject to strict oversight and safeguards against double-counting and greenwashing.

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

See below Eurometaux's key messages, and attached our more detailed position on the carbon price paid in third countries. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, ferro-alloys, among other energy transition metals. Key points: 1.

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

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

Sir / Madam, MSCI would like to thank the European Commission for providing us an opportunity to respond to the call for evidence on Carbon border adjustment mechanism (CBAM) - carbon price paid in a third country. Please find attached our response to the call for evidence. If there are any clarifications required on our submission, you may please reach out to me. We would be happy to discuss.

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

It is not clear whether the EU approach is based upon the import of goods, and the way to bring CO2-certificates into calculation. One possibility is to import goods and purchase CO2-certificates in the country of origin at the price for CO2-certificate in the country of origin or Second possibility to expect that a price for CO2-certificat shall be the "within-EU-price" for this certificate.

the declarant should only retrieve the official documentation or evidence issued by the supplier that could be 1. Official certificates or receipts or Documents issued by the competent authorities of the third country attesting the payment of carbon or emissions (e.g.

Filed in Italian · English published by the European Commission

Article 9(4) empowers the Commission to define rules for recognising foreign carbon prices. For ESPA, this provision is not a matter of trade defence, but an essential element to ensure that the CBAM remains an environmental instrument aimed at delivering a fair carbon cost signal.

The carbon price paid in the country of origin must have been certified by a third body listed by the European Commission in order to avoid allegations that are difficult to verify. If a producer pays carbon in its country of origin, it is imperative to declare actual resignations according to the CBAM methodology, certified by a third party body. It shall not be able to use default values.

Filed in French · English published by the European Commission

Subject: Proposal for the CBAM Formal Phase Rules to Recognize China's Green Electricity Trading Main Content: Our company is an iron and steel enterprise engaged in the production of automotive steel sheets, silicon steel, and other products, with part of its products sold to Europe. We are actively advancing the dual-carbon strategy and implementing energy consumption transformation.

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

Subject: Proposal to Recognize China's Green Power Trading in CBAM's Indirect Carbon Emission Accounting. Our company name is Kitron Electronics Manufacturing(Ningbo)Co.,ltd. Kitron is a leading Scandinavian Electronics Manufacturing Services (EMS) company, delivering improved flexibility, cost efficiency, and innovation power through the value chain.

The deduction for the carbon price paid in the country of origin plays an important role in the equation calculating the final CBAM costs. In order to ensure the environmental integrity of the CBAM and its effectiveness in ensuring a level playing field for European producers, it is essential that a very cautious and conservative approach is adopted in recognising the carbon price in the country of origin.

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

Clear and transparent rules should be laid down on how carbon prices paid in third countries are converted into CBAM certificates. Predictability is particularly important so that companies can reliably calculate their cost planning, procurement decisions and mitigation strategies. In that regard, responsibility for such credit must be clearly defined.

Filed in German · English published by the European Commission

UFE supports the principle underlying the Carbon Border Adjustment Mechanism, as it aims to preserve the competitiveness of European industry and to prevent carbon leakage, in a context of increased climate ambition at European level. However, in the case of electricity imports, UFE has identified two main issues that should be addressed with regard to the carbon price paid in a third country.

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

Our submission highlights that while embedded emissions in renewable hydrogen production (and related hydrogen-derived commodities) are, in principle, much lower than for fossil-based hydrogen, they can under certain circumstances be comparable or even greater. The challenge of accurately accounting for grid-related emissions (Scope 2) has been addressed through the three pillars approach.

Provisions on Deduction of Carbon Prices Paid in Third Countries Recommendation: The conversion rules should clearly specify whether the real-time exchange rate at the time of payment or the average exchange rate for a certain period (e.g., the average of the previous quarter) is adopted, and consistency should be maintained.

Ensuring fair recognition of carbon pricing instruments applied in third countries is essential both for WTO compatibility and for maintaining international legitimacy of the CBAM framework. As most jurisdictions levy carbon costs at the installation level, the regulation must establish a harmonised methodology to allocate such costs to individual CBAM-covered commodities.

Subject: Proposal to Recognize China's Green Power Trading in CBAM's Indirect Carbon Emission Accounting Main Content: Our company is a global manufacturer of power and electrical products, with its headquarters located in Europe. We have been advancing sustainable development and have released the company's carbon reduction commitments. To this end, we deployed a rooftop solar photovoltaic (PV) system in 2017.

Our company is producing gas products using low carbon power produced in China. In the passed several yrs, we signed longterm PPA with dedicated sourcing of REN projects which can be well tracked and we will get the boundled EAC called GECs which is clearlly measured and controlled with timely issurance from the central govermenet.

I. Embedded Emissions Accounting Methodology Recognition mechanism for electricity emission factors equal to zero Issue: How can green, nuclear or other power be recognised as zero-carbon electricity? Recommendation: The EU should explicitly accept Guarantees of Origin (GOs) + power purchase agreement or third-party certification as valid evidence, preventing operators from being forced to apply high default factors…

Greenlink Interconnector Ltd, the owner of an electricity interconnector between Ireland and Great Britain (GB). Electricity is a unique commodity in CBAMs scope, traded within an interconnected network where flows cannot be physically traced.

Europacable welcomes the opportunity to respond to the call for evidence on the carbon price paid in a third country for the CBAM. A study commissioned by Europacable in 2023 confirmed that aluminium power cables are a key technology to empower Europes decarbonisation.

The recognition of the carbon price already paid in third countries can be a useful tool to avoid double taxation, but it requires very strict criteria. It represents a critical and potentially dangerous aspect of the CBAM, which Confapi rejects in its current design.

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

Adjustment for carbon prices paid in a third country (The method of adjusting CBAM obligations where a carbon price has been paid in the country of export, pursuant to Article 9 of Regulation (EU) 2023/956) On the implementing guidance concerning the adjustment for carbon prices paid in a third country, Viet Nam requests that the EU specify in detail certain conditions under Article 9(1) in order to benefit from a…

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

Executive summary: WE Soda strongly supports the creation of a clear, consistent, and legally certain framework for the Carbon Border Adjustment Mechanism (CBAM) that allows for the deduction of carbon prices paid in third countries. We urge the EU Commission to establish specific rules for converting a carbon price paid in a third country, such as Türkiye, into a corresponding number of CBAM certificates.

While reaffirming Fincantieris well-known position of support for decarbonization objectives, but also concern regarding the implementation mechanisms of the CBAM that could negatively affect the specific shipbuilding sector for which we request an exemption due to its strategic importance and particular characteristics (see analysis, rationale, and proposals in the attached note) we are certainly in favor of…

o Clarification is needed on the carbon price paid in third countries, especially in regard to which schemes, in which jurisdictions, to which extent (% of covered emissions) and under which conditions will be accepted. For example: Will payments under Chinese ETS be accepted for CBAM purposes and if so, how? How should emissions paid in third countries at organizational level be allocated to individual products?

Some industries covered by the CBAM mechanism have already fulfilled their carbon emission obligations in the national carbon market or sub-national carbon markets. To better align with existing carbon market mechanisms, it is recommended that carbon prices from both national and sub-national carbon markets be included in the scope of carbon price deduction under CBAM.

The deduction of third-country carbon prices is vital to avoid double taxation and ensure CBAMs legitimacy. The EU must adopt an inclusive definition of carbon pricing, recognizing carbon taxes and intensity-based ETS schemes, such as Chinas, as long as they impose real financial costs. Compensation should be deducted only if directly linked to the carbon pricing system, not general subsidies.

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

The non-EU carbon tax calculation mechanisms might differ from those in Europe. In addition, many countries still do not apply this tax. Suppliers may not provide them to the importer or use false documentation. In this case, there would be a need for a harmonised system for calculating emissions at global level, but unfortunately hardly applicable.

Filed in Italian · English published by the European Commission

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

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

Attached is the Ministry of Economic Affairs, Republic of China (Taiwan), paper outlining our comments and recommendations on this consultation. 1.Public consultation on deduction rules. After publishing the draft regulation on deducting CBAM obligations for third-country carbon prices, the Commission should run a consultation to build consensus, ensure transparent implementation, and protect stakeholder rights.

Subject: Commentary on the European Commission's Call for Evidence for the Carbon Border Adjustment Mechanism (CBAM) Implementing Acts on Deduction of Carbon Price Paid in a Third Country (Article 9) The Thailand Greenhouse Gas Management Organization (Public Organization) (TGO) would like to extend its warm appreciation to the European Commission for initiating the official consultation on the implementing acts for…

Návrh na zahájení projednání v CBAM O uhlíkový daň CO2 ať zakotvení v číslo IČO obce Hrádek okres Frýdek-Místek [phone removed]: A další instituce v vnitrostátní regionální samosprávy EU ať platí část zodpovědnost přenese v formě příspěvků nebo poplatků v CBAM v 70-140%. Cena v povolenky v 45 eur bude krátkodobé období 2027. Cena 85-90eur.

Lufthansa Technik fully supports European initiatives for further CO2 reduction as this is a vital part of our own environmental targets. We also understand that it is a great step forward towards reduction of bureaucratic efforts to introduce the Omnibus regulation with the new threshold for many companies.

The Polish Steel Association supports EUROFERs position regarding the carbon price deduction mechanism under CBAM. To ensure fairness and environmental integrity, only effective, explicit and net carbon costs paid in the country of origin should be recognised. Recognised carbon costs must apply to the entire domestic production and be part of a transparent, robust and ambitious climate policy framework.

Although not currently in the inclusive sector in the studies in the CBAM field, considering that our sector will be included in the short or medium term due to the involvement of our stakeholders in the relevant mechanism, the types of documents and third-party verifier criteria for the verification of carbon prices paid in third countries can be clearly defined.

This initiative will establish rules for converting the carbon price paid in a third country for declared embedded emissions into a corresponding number of CBAM certificates. These rules will take into account any form of compensation or support mechanisms available in the third country that effectively reduce the carbon price.

SSE is a leading energy provider headquartered in UK and operating in multiple EU countries. Emissions factor for electricity Electricity differs from the other goods in CBAMs scope, as electricity is an interconnected networked system where electrons cannot be easily traced and are traded anonymously.

As IVSH we welcome the Commissions initiative to set rules for converting third-country carbon prices into CBAM certificates. However, we would like to emphasize once again a key point from our previous input on the downstream extension: For CBAM to achieve its climate and competitiveness objectives, it is essential to fully include downstream goods such as cookware, cutlery, and other metal-intensive household…

As a large multinational corporation, we fully support the objectives of the European Green Deal and the EUs efforts to prevent carbon leakage. We recognize the importance of ambitious climate action and the need for a level playing field for European industry. However, we would like to highlight several significant challenges with the current implementation of the CBAM regulation: 1.

CELSA Group, as one of Europes leading steel producers, welcomes the opportunity to contribute to the consultation on the Carbon Border Adjustment Mechanism rules on the deduction of the carbon price paid in a third country. CELSA Group strongly supports enhancing the Carbon Border Adjustment Mechanism (CBAM) to ensure robust protection against carbon leakage.

Gerber Steel GmbH respectfully submits its position on the initiative Carbon border adjustment mechanism (CBAM) - carbon price paid in a third country. The attached statement sets out our assessment of the proposed approach and provides recommendations to ensure WTO-compliance, fairness for SMEs, and the avoidance of double taxation. We are, of course, available at any time for queries and consultations.

The initiative will establish a set of rules to convert the price paid in a third country for the declared embedded emissions into a corresponding number of certificates of the CO2 adjustment mechanism at the border, taking into account any form of compensation available in that country leading to a price reduction.

Filed in Italian · English published by the European Commission

Policy should be recognising only effective, explicit and net carbon price paid in countries of origin with ambitious, transparent and robust climate legislation. The deduction for the carbon price paid in the country of origin plays an important role in the equation calculating the final CBAM costs.

ASSOFERMET expressed his support for maintaining the current legal framework, as defined in Article 9 of Regulation (EU) 2023/956 of the European Parliament and of the Council of 10.5.2023. In particular, the Association recognises the importance of ensuring continuity and stability of the regulatory framework currently in place, considering it to be consistent with the ecological transition and competitiveness…

Filed in Italian · English published by the European Commission

The publication does not clearly outline how a potential third-country certificateissued in cases where carbon pricing has been paid in the country of originis to be administered, verified, and approved by the receiving parties. This requires further clarification to ensure transparency and consistency in implementation.

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

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

Environmental protection is important. No question. But please think. CBAM is intended to compensate for the oath for products produced outside the EU. It means less and less red tape. However, the EU is building more and more bureaucracy. Why the compensation cannot take place through customs duties or the like. This would save the bureaucratic burden of burdensome declarations.

Filed in German · English published by the European Commission

Ladies and gentlemen, the main issue of CBAM is, in my view, that it is far too complex and bureaucratic from the point of view of the company. The compensation itself makes sense in any case, but the third countries, which now have to provide the data, are unfortunately not so far in terms of accounting for emissions.

Filed in German · English published by the European Commission

Proof of the carbon price paid locally (if there is a carbon pricing mechanism or local taxes). Claiming a deduction equivalent to the European free allocation from the CBAM certificate. Submitting accurate and documented emissions reports so that they are accepted by the European Union.

Proof of the carbon price paid locally (if there is a carbon pricing mechanism or local taxes). Claiming a deduction equivalent to the European free allocation from the CBAM certificate. Submitting accurate and documented emissions reports so that they are accepted by the European Union.

Our feedback proposes integrating the Carbon Border Adjustment Mechanism (CBAM) with the European Trade Indexes Registry (EUTIR) to create a trusted, interoperable digital foundation for carbon price deduction and compliance.

Governments are beginning to endorse high-quality carbon credits, including credits with a CCP label from the ICVCM as well as credits issued under Article 6 of the Paris Agreement. The Coalition to Grow Carbon Markets counts France and the UK among its signatories. Currently, many credits are traded OTC without price transparency or visibility.

As CarbonEmit, we actively support companies in fulfilling their CBAM reporting obligations. Based on the challenges observed among our client firms, we would like to highlight the following issues and recommendations. Concerning the recognition of carbon prices paid in third countries, existing uncertainties make it difficult for importers to plan their costs.

The inclusion of a carbon price that has already been paid in a third country should be as straightforward as possible, since small suppliers often refrain from providing additional documentation or preparing additional data. They do not understand the CBAM regulation nomenclature. The EU Commission should acquire information about carbon tax regulations from third countries that have already implemented them.

As Sustainabilios, we provide consultancy services to a wide range of industrial companies in Türkiye on carbon management and CBAM preparedness. Drawing on our field experience, we would like to respectfully submit the following observations and recommendations: Carbon pricing policies in Türkiye are evolving rapidly.

Feedback from Tangelic: CBAM Implementation and African Carbon Markets Tangelic is a U.S.-registered nonprofit advancing clean energy access, climate finance, and sustainable development across Africa. We work at the intersection of clean energy infrastructure, carbon markets, and policy design, ensuring that climate action delivers both emissions reductions and equitable growth in the Global South.

Feedback: Regarding implicit emissions and power emission factors: If indirect emissions are to be included, the values should be determined based on the actual emission factors of each region, and the differences in electricity sources across various industries should be taken into account to ensure fairness.

Regarding the carbon price paid in a third country, we hope the following aspects can be clarified: 1. Clarify the method for apportioning the carbon price at the third-country organization level to the product level: Most countries levy carbon prices based on installation-level emissions.

The CBAM cannot be limited to an accounting calculation of the carbon price paid in a third country. This vision, pushed by cemented and asphalt wolves, invisibilises the real impact in regions such as the Canary Islands, where forced consumption of imported cement and bitumen prevents the use of local limestone sands or circular polymers that would save emissions and costs.

Filed in Spanish · English published by the European Commission