Amcor Flexibles EMEA

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?

o To accurately represent the emissions currently captured in EU ETS, only direct emissions from aluminum should be considered. o Is it crucial to allow the unconditional use of default values to minimize administrative burdens and prevent disruptions to European businesses.

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