Sandbag

The Circular Economy Act represents an opportunity to move beyond the EUs current fragmented waste policy and embed circularity as a core pillar of Europes industrial and climate strategy, creating the harmonised, predictable conditions needed for circular business models.

Labelling schemes are a source of debate with the proponents of each scheme claiming that the schemes either favour the ore-based or the scrap-based route of production. Without delving into the details of relative advantages of each labelling scheme, we recommend 4 principles and key criteria that should be included in any steel-related labelling scheme used to determine the incentives and support from EU and…

Sandbag welcomes the opportunity to contribute to the public consultation on the European Commissions proposed revision of the benchmark values of free allocation of emission allowances (2026-2030). This response to the Commissions public consultation outlines a sector-by-sector analysis of the Commissions proposal.

Sandbags recommendations: - For steel and aluminium, address scrap-related circumvention by either: Attributing emissions to both pre- and post-consumer scrap, and including scrap as a CBAM-covered input and applying country-level default values, or Using systematic default values - For cement: Apply systematic default values, to prevent resource reallocation without real emissions reductions - Improve indirect…

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.

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.

Our recommendations: - For steel and aluminium, Address scrap-related circumvention by either: o Attributing emissions to both pre- and post-consumer scrap, or o Using systematic default values - For cement, Apply systematic default values, to prevent resource reallocation without real emissions reductions - Improve indirect emissions accounting Either replace plant-level electricity emissions reporting with a…

We agree with the European Commissions general diagnosis that increasing the share of electricity in overall energy consumption is necessary to achieve deep decarbonisation. However, it is not sufficient. If overall energy use increases, or if electricity generation does not decarbonise rapidly, then electrification may fail its decarbonisation role.

The proposed approach using CBAM benchmarks is surprisingly complex. A different approach (which we had assumed as the obvious solution) would consist of simply mirroring the EU ETS. In the ETS, there is no such thing as a steel benchmark, so the allowances given for the production of steel are dispatched between individual process.