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Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

Climate action, Customs, Energy

This initiative down detailed rules on how carbon border adjustment mechanism (CBAM) certificates to be surrendered by authorised CBAM declarants shall be adjusted to reflect the extent to which EU emission trading schemes (ETS) allowances are allocated free of charge. These rules should be elaborated taking into account the principles applied in the EU ETS.

Links

Public consultation

ID: 14829

Lobbying Activity

48 responses

Chemical industry urges maintaining free allowances until CBAM proves effective

European Chemical Industry Council, 25 Sept 2025

Cefic requests maintaining high free allowances and indirect carbon cost compensation until CBAM proves reliable. They want methodologies covering the full 45,000-chemical value chain to prevent unfair disadvantages for downstream installations.
This would protect them from competitive disadvantage against non-EU producers without carbon pricing.
Climate advocates lose faster emission reductions from eliminating free pollution permits.

European Steel Association urges stricter environmental benchmarks in CBAM implementation

The European Steel Association, 24 Sept 2025

The association requests that CBAM benchmarks reflect best environmental technologies, ensure fuel/electricity exchangeability for EAF steel, apply scrap EAF benchmarks to all long product imports, and reflect lowest virgin ferro alloy content in stainless steel.
This would strengthen their competitive position by ensuring importers face equivalent carbon costs.
Third-country steel producers using carbon-intensive processes face higher CBAM costs and reduced market access.

ArcelorMittal urges stricter CBAM benchmarks to reflect best environmental practices

ArcelorMittal, 19 Sept 2025

The company requests that CBAM benchmarks reflect best environmental technologies to incentivize switching from carbon-intensive processes. They want EAF steel benchmarks to consider fuel/electricity exchangeability, scrap EAF benchmarks applied to all long product imports, and stainless steel benchmarks reflecting lowest virgin ferro alloy content.
This would strengthen their competitive position by ensuring importers face equivalent environmental standards.
Third-country producers using carbon-intensive methods face higher compliance costs and reduced market access.

EU Fuel Industry Urges Commission Handle CBAM Complexity

FuelsEurope, 18 Sept 2025

FuelsEurope requests that EU authorities handle the complexity of free allocation calculations rather than requiring third-country operators to perform them. They argue the obligation to calculate equivalent free allocation using production data would hinder the mechanism and impose undue burden on non-EU operators.
This would protect their members from complex compliance requirements when exporting to the EU.
EU authorities would face increased administrative burden managing calculations for third-country operators.

Eurometaux demands strict carbon border benchmarks to prevent loopholes

EUROMETAUX, 25 Sept 2025

Eurometaux insists carbon border standards must mirror the European system's strict monitoring and climate-friendly benchmarks. They argue benchmarks should be updated regularly and designed to prevent importers from exploiting exemptions or loopholes.
This would protect European metal producers from unfair competition by carbon-intensive foreign imports.
Importers using scrap or specific alloys may lose the ability to avoid carbon costs.

European Aluminium urges pause on CBAM implementation for sector

European Aluminium AISBL, 25 Sept 2025

The organization requests a pause on CBAM implementation for aluminium until key improvements are made. They advocate for a single default value approach for all aluminium goods based on primary production emissions, with no distinction for scrap content. They oppose including indirect emissions in CBAM calculations.
This would protect their competitive position by ensuring importers face comparable carbon costs.
Climate advocates lose stricter carbon accounting that would better reflect actual emissions.

RWE calls for robust CBAM benchmarks to prevent importer loopholes

RWE AG, 25 Sept 2025

RWE requests accelerated implementation of CBAM rules before January 2026. They demand that CBAM benchmarks mirror EU ETS stringency to prevent importers from exploiting loopholes through minor product adjustments while EU installations must make significant emission reduction investments.
This would protect them from unfair competition with importers exploiting regulatory loopholes.
Importers lose the ability to undercut EU producers through minor compliance workarounds.

European Cement Industry Seeks Alignment of CBAM with ETS Binder Benchmark

CEMBUREAU - The European Cement Association, 25 Sept 2025

The industry requests that CBAM benchmark calculations align with the EU ETS binder benchmark introduced in 2026. They propose a formula multiplying the ETS benchmark by CBAM and correction factors, then by clinker-to-cement ratio. They highlight the complexity of accounting for alternative hydraulic binders in imported cement.
This would ensure their CBAM obligations match the benchmark used for their free ETS allocations.

Fertilizers Europe demands strict carbon border rules for importers

Fertilizers Europe, 25 Sept 2025

The group wants CBAM to eliminate "resource shuffling" and ensure importers face the same indirect emission costs as EU firms. They advocate for high default emission values on imports to incentivize accurate data reporting. Additionally, they call for strict alignment between CBAM and existing EU emissions trading rules.
Stricter import rules would protect European manufacturers' market share from cheaper, higher-carbon foreign competitors.
Foreign exporters lose their competitive advantage of operating in regions with low or no carbon costs.

Bouygues urges stability in CBAM implementation for multi-year construction projects

BOUYGUES EUROPE, 25 Sept 2025

The company requests urgent clarity on CBAM implementation rules and calculation methods. They emphasize the need for stable, long-term provisions to enable accurate cost assessment for multi-year construction projects.
This would provide cost certainty for their multinational subsidiaries bidding on long-term construction contracts.

Air Liquide warns CBAM creates unfair advantage for insourced hydrogen

AIR LIQUIDE, 25 Sept 2025

The company urges the European Commission to restore level playing field between outsourced and insourced hydrogen production. They want hydrogen outsourced by non-CBAM sectors to receive the same free allowances as insourced hydrogen would get.
This would prevent loss of competitiveness and significant business losses for industrial gas suppliers.
Industries that self-produce hydrogen lose their cost advantage over specialized suppliers.

Environmental coalition backs swift CBAM rollout, warns against watering down rules

Environmental Coalition on Standards, 25 Sept 2025

The organization calls for regulatory stability and timely CBAM implementation in 2026. They urge basing calculations on existing ETS benchmarks rather than creating new CBAM benchmarks, and warn against allowing easier use of average emission values that could undermine environmental integrity.
This would preserve strong climate protections and support EU industrial frontrunners who invested in decarbonization.
Heavy industrial emitters lose the ability to evade carbon costs using favorable default values.

European Tyre Industry Urges Energy-Based CBAM Benchmarks Over Emissions

European Tyre & Rubber Manufacturers' Association, 25 Sept 2025

The organisation requests that CBAM benchmarks use energy consumption intensity instead of emissions intensity. They argue current EU ETS methodology favours polluting processes and penalises installations using cleaner alternatives like renewable electricity. They also seek better reflection of trade intensity in carbon leakage calculations and clear methodologies for recognising carbon prices paid abroad.
This would allow tyre manufacturers using renewable electricity to receive free allowances currently denied to them.
More polluting manufacturers lose preferential treatment under current emissions-based methodology.

Norsk Hydro urges tougher CBAM rules to mirror EU ETS carbon costs

Norsk Hydro, 19 Sept 2025

Hydro requests strengthening CBAM methodology to close loopholes, assign emissions to scrap, exclude indirect emissions for aluminium, and keep electricity rules enforceable. They argue CBAM must ensure imported goods face the same carbon costs as European production without circumvention incentives.
This would prevent imported aluminium from avoiding carbon costs European producers pay on scrap and electricity.
Third-country aluminium producers lose ability to exploit scrap loopholes and certificate exemptions to avoid CBAM costs.

Bellona urges no delays in phasing out EU carbon credits

Bellona Europa, 25 Sept 2025

The organization demands the phase-out timeline remain unchanged without extensions. They argue free allowances have delayed industrial transformation for two decades and weakening the transition would jeopardize EU climate goals.
This would accelerate the carbon price signal driving investments toward their preferred low-carbon technologies.
Carbon-intensive industries lose cost advantages from free pollution permits worth billions annually.

Outokumpu demands CBAM benchmarks reflect best environmental technologies

Outokumpu Oyj, 25 Sept 2025

The organization requests that CBAM benchmarks reflect the best environmental technologies and processes. They specifically propose that stainless steel benchmarks reflect the lowest content in virgin ferro alloys.
This would protect the company's competitiveness by ensuring importers face similar carbon costs.
Importers using carbon-intensive production methods would face higher financial obligations at the border.

Gerber Steel urges two-year suspension of complex CBAM rules

Gerber Steel GmbH, 22 Sept 2025

The firm recommends a two-year postponement because missing benchmarks make cost calculations impossible. They also suggest fully abolishing free certificates to create a level playing field for importers.
Suspending the measure would protect steel importers from insolvency and massive retroactive tax burdens.
European consumers face higher costs because the carbon mechanism acts as an internal tax.

Orlen demands robust rules to prevent CBAM circumvention

Orlen S.A., 25 Sept 2025

Orlen calls for a robust methodology based on actual emissions data to prevent manipulation by dishonest entities. They emphasize that CBAM must complement existing carbon leakage protections to support European industry resilience.
These measures would protect Orlen’s market position against international competitors with lower environmental costs.
European exporters risk losing global market share if CBAM creates unequal competition conditions abroad.

Solvay Urges Full Free Allowances for Exported CBAM Products

Solvay SA, 25 Sept 2025

Solvay requests a CBAM benchmark methodology that replicates the EU ETS system. They specifically demand maintaining 100% free allowances for European products destined for export markets.
This would protect their international market share and ensure long-term decarbonization investments remain profitable.
Foreign producers would face stricter verification requirements and reduced allocations when using green technologies.

Polish business group urges delay in ETS allowance phase-out

Związek Pracodawców Business & Science Poland, 25 Sept 2025

BSP requests prioritizing verified emissions data over default values for fair competition. They also urge deferring free allowance phase-outs until 2030 to protect exports.
This would protect Polish energy-intensive industries from cost asymmetries and potential carbon leakage.
Foreign producers would lose the ability to use simplified, underestimated carbon values for imports.

Metal Packaging Europe urges process-specific benchmarks for CBAM

Metal Packaging Europe External Affairs ASBL, 25 Sept 2025

MPE requests that free allocation remains available until an export solution is found. They advocate for differentiating benchmarks by production processes and including emissions from downstream activities to prevent circumvention.
These adjustments would protect the international competitiveness and resilience of the European packaging industry.
Exporters of high-carbon products would lose exemptions if the inward processing procedure is abolished.

CELSA Group urges EAF-based benchmarks for all steel imports

CELSA Group, 22 Sept 2025

CELSA Group proposes introducing a Free Allocation Adjustment so that EAF steel benchmarks are used for all steel long product imports. They also state that benchmarks must consider fuel and electricity exchangeability to ensure consistency with emissions scope.
This would eliminate the unintended competitive advantage currently enjoyed by specific steel imports.
Importers of DRI-EAF products lose their competitive advantage over EU-based scrap plants.

IFIEC Europe urges stronger safeguards and CBAM export solutions

IFIEC Europe, 25 Sept 2025

The organization calls for maintaining free allowances and indirect carbon cost compensation to prevent industry relocation. They demand the Commission propose a legislative solution for exporters and align CBAM benchmarks with EU ETS methodology.
These changes would protect the competitiveness of European industrial sectors and reduce relocation risks.
European manufacturers lose international market share as free allocations are gradually reduced.

Consultation response

European Steel Processors Association, 25 Sept 2025

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. Evidence from ETS phase 3…

Polish Steel Association calls for stricter importer carbon benchmarks

Hutnicza Izba Przemysłowo-Handlowa, 23 Sept 2025

The group demands benchmarks based on the best environmental practices to ensure fair competition. They suggest using scrap-based standards and minimizing emission factors for stainless steel.
Aligning benchmarks with cleaner processes protects the competitiveness of European steel manufacturers.
Foreign producers using carbon-heavy technologies will face higher costs to enter Europe.

German cement industry demands strict parity between CBAM and ETS

Verein Deutscher Zementwerke e.V., 25 Sept 2025

The VDZ demands CBAM obligations be based on verified real embedded emissions. They argue deductions should strictly reflect the benchmark-based free allocation given to European producers. This ensures imported products do not receive more favorable treatment than domestic goods.
This protects European manufacturers by preventing high-carbon imports from undermining their market competitiveness.
Non-EU importers lose financial advantages if their carbon cost deductions are strictly capped.

Consultation response

GravitHy, 24 Sept 2025

GravitHy welcome the Commissions initiative to clarify the implementation rules of the CBAM. For first-of-a-kind industrial projects such as ours, regulatory clarity and predictability are essential to unlock investment and ensure that Europes decarbonization objectives translate into industrial…

Industrial gas association seeks fair carbon rules for hydrogen

European Industrial Gases Association AISBL, 25 Sept 2025

The organization calls for regulatory adjustments to ensure outsourced hydrogen production receives the same free allowances as insourced production. This aims to maintain a level playing field between different business models in the refining and chemical sectors.
This adjustment prevents a projected 1.5 billion EUR loss for the industrial gas sector.
Self-producing refineries lose their relative tax advantage over competitors that outsource hydrogen production.

Sandbag urges product-based benchmarks to close steel carbon loopholes

Sandbag Climate Campaign, 25 Sept 2025

The group proposes replacing process-based benchmarks with product-based ones for steel. This ensures equal treatment for imports and stops incentivizing polluting production over recycling.
This shift would align EU carbon policy with the organization's climate advocacy goals.
Producers using iron ore and coal lose advantages over cleaner scrap-based recyclers.

Glass Alliance Europe demands robust carbon border rules for industry

GLASS ALLIANCE EUROPE AISBL, 25 Sept 2025

The association calls for CBAM to cover manufacturing, electricity, and transport emissions with robust verification. They urge the Commission to apply high default values for importers who fail to report data.
This would prevent foreign competitors from undercutting EU prices through lower environmental costs.
Non-EU manufacturers in carbon-intensive countries would face significantly higher costs and stricter reporting.

Consultation response

Emerson Electric Co., 24 Sept 2025

Thank you for the opportunity to provide feedback. Please see the attached document.

UNESID urges CBAM benchmarks to protect European steel recycling

Unión de Empresas Siderúrgicas, 25 Sept 2025

UNESID demands benchmarks account for European recycling and indirect costs to ensure fair competition. They call for rules preventing exporters from dodging costs through minor product modifications.
This would protect European low-carbon producers against artificially cheap, high-emission imports.
Foreign exporters using gas-based production would face significantly higher carbon fees.

Consultation response

International Emissions Trading Association, 25 Sept 2025

The International Emissions Trading Association (IETA) welcomes the opportunity to provide input on the Commissions Call for Evidence regarding the adjustment of CBAM obligations to account for the free allocation of EU ETS allowances. The response underlines the importance of timely adoption of…

Consultation response

EUROMETAL, 24 Sept 2025

EUROMETAL supports CBAM as a cornerstone of EU climate and trade policy. Its success depends on the clarity and stability of rules, the adoption of workable methodologies adapted to SMEs in steel distribution, fair recognition of carbon prices paid abroad, proportionate and harmonised reporting…

ECGA demands continued free allowances until CBAM is proven

European Advanced Carbon and Graphite Materials Association, 25 Sept 2025

Free allocation must remain until the border mechanism is proven to safeguard competitiveness. The system must include Scope 2 electricity emissions in its methodology.
Maintaining free allowances prevents carbon leakage and protects profit margins for European producers.
EU importers will be penalised if they source from producers using clean energy abroad.

Consultation response

Hydnum Steel, S.L., 25 Sept 2025

As the first ultra-clean steelmaking facility in Spain, Hydnum Steel strongly supports the CBAM and welcomes the European Commissions efforts to drive global decarbonization in steel and other essential sectors. Please find attached our contribution to the public consultation on the CBAM. We hope…

Consultation response

"Business for CBAM Coalition", 25 Sept 2025

Please find attached the submission of the Business for CBAM Coalition. You can find more information on the Business for CBAM Coalition and its members on the website: https://www.businessforcbam.eu

Consultation response

Lithuanian Business Confederation, 25 Sept 2025

Lithuanian Business Confederation (LVK) submits its position to the ongoing European Commission consultations on the Carbon Border Adjustment Mechanism (CBAM). The document outlines key challenges for businesses, emphasizes the need for proportional and carefully assessed implementation, and…

Consultation response

Ammonia Europe, 24 Sept 2025

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of the CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start…

Polish chemical industry demands free allowances until 2030

Polska Izba Przemysłu Chemicznego, 25 Sept 2025

The organization requests maintaining free emission allowances until at least 2030 to prevent carbon leakage. They urge delaying the phase-out until CBAM effectively protects exports and proves its functionality.
Maintaining free allowances prevents a sharp increase in operating costs and preserves international competitiveness.
Environmental groups and climate targets lose if the transition to full carbon pricing is delayed.

Consultation response

Industrieverband Schneid- und Haushaltwaren, 22 Sept 2025

As IVSH we welcome the Commissions initiative regarding CBAM certificates and adjustements. However, we would like to emphasize once again a key point from our previous input on the downstream extension: For CBAM to achieve its climate and competitiveness objectives, it is essential to fully…

Consultation response

Adolf Würth GmbH Co. KG, 25 Sept 2025

Die Würth-Gruppe unterstützt das Ziel der Kommission, mit der Anpassung der CBAM-Verpflichtungen eine Gleichbehandlung von in der EU und in Drittländern hergestellten Waren zu gewährleisten. Von besonderer Bedeutung ist dabei die Berücksichtigung der kostenlosen Zuteilung von EU-EHS-Zertifikaten,…

Consultation response

, 25 Sept 2025

Federacciai, the Federation of Italian steel companies, welcomes the opportunity to give its contribution to this consultation. Federacciai fully supports Eurofer's position on this topic, as outlined in the attached paper

Consultation response

European Fertiliser Blenders Association, 25 Sept 2025

Please find enclosed the response from the European Fertiliser Blenders Association (EFBA) on the implementing act on free ETS allowances.

Consultation response

Confederazione Italiana della Piccola e Media Industria Privata, 24 Sept 2025

The gradual phase-out of free allowances under the EU ETS system, scheduled between 2026 and 2034, represents a crucial transition that coincides with the full entry into force of the CBAM. The implementing act under Article 31 of Regulation (EU) 2023/956 must clearly define how free allocation…

Consultation response

, 24 Sept 2025

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…

Consultation response

Federation of Egyptian Industries - Environmental Compliance Office, 24 Sept 2025

Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the…

Consultation response

DigitalTrade4.EU, 12 Sept 2025

Our feedback proposes integrating the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to strengthen the implementation of the Carbon Border Adjustment Mechanism (CBAM). By anchoring emissions data, EU ETS free allocation benchmarks, and foreign carbon price…