European Steel Processors Association

The European Steel Processors Association (ESPA) welcomes the European Commissions Regulation establishing a framework of measures for the acceleration of industrial capacity and decarbonisation in strategic sectors: the Industrial Accelerator Act (IAA).

The European Steel Processors Association (ESPA) welcomes the EUs efforts to strengthen the Carbon Border Adjustment Mechanism (CBAM) as a key tool to prevent carbon leakage and support the decarbonisation of the steel sector. ESPA supports extending CBAM to downstream products to address carbon leakage risks across the value chain and advocates for robust anti-circumvention measures to ensure effectiveness.

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.

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.

Article 7(7) requires embedded emissions to be calculated according to harmonised rules; Article 9(4) demands that benchmarks used for adjustments mirror ETS; Article 10(2) ensures uniformity of conditions. These provisions form a legal obligation: CBAM cannot diverge from ETS logic. Actual values and defaults ESPA strongly supports that actual values, verified under ETS-consistent MRV systems, remain the rule.

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