Oriatec

On behalf of Beijing Oriatec Co., Ltd., a China-based institution specializing in CBAM compliance consulting and training, we respectfully provide recommendations on the European Commissions proposal to extend the scope of the CBAM. These suggestions draw upon two years of practical experience and research with exporters.

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.

The methodology for national monitoring under CBAM must be fair, practical, and differentiated. While accuracy in calculating direct embedded emissions is important, mandatory precision monitoring imposes unsustainable burdens on SMEs. A tiered approach should be adopted: large enterprises using precise monitoring, SMEs using EU-approved default values with a transition period.

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