WE Soda Ltd

This submission addresses a structural flaw in the EU Emissions Trading System that creates a concrete risk of double allocation within the synthetic soda ash/glass value chain. This risk, if left unaddressed, would undermine the environmental integrity of the system and distort competition across the value chain.

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.

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.

WE Soda urges the EU Commission to expand the Carbon Border Adjustment Mechanism (CBAM) to include the soda ash and glass industries in line with the EU policy objectives. We call for an integrated assessment and design of CBAM benchmarks to ensure low-carbon soda ash is treated fairly.

Executive summary: WE Soda urges the EU Commission to expand the Carbon Border Adjustment Mechanism (CBAM) to include the soda ash and glass industries in line with the EU policy objectives. WE Sodal also calls for an integrated assessment and design of CBAM benchmarks to ensure that low-carbon soda ash has a level playing field with high-carbon soda ash produced in Europe.