Stichting I-REC
The International Tracking Standard Foundation (I-TRACK Foundation) aims to improve energy markets worldwide by standardizing Attribute Tracking Systems so that organizations can purchase and reliably claim the origin of their product.
ID: 456089792112-70
Lobbying Activity
Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period
23 Sept 2025
Call for Evidence for an Impact Assessment 24 September 2025 Carbon Border Adjustment Mechanism (CBAM) CBAM implementation: rules on the methodology for calculating emissions embedded in CBAM goods; rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation; rules on the deduction of the carbon price paid in a third country The International Tracking Standard Foundation welcomes the adoption of the European Commissions Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) in May 2023. This can be seen in our previous consultation response seen here: I-TRACK-Foundation_Consultation-CBAM_Final.pdf In this consultation response we praised the admirable achievement made by implementing the first ever CBAM mechanism. A mechanism that is already under discussion to be replicated in the United Kingdom, Australia, Canada, Turkey, Brazil and China. Even the United States, however unlikely, is considering a Foreign Pollution Fee similar to the CBAM in Europe. This consultation, however, hits the nail on the head related to the problem with CBAM as it is currently defined and it is an area that is embedded in the mission of our organization. As currently proposed, the CBAM threatens the goal of encouraging local renewable energy use in non-European countries. If a CBAM adherent products embedded emissions are calculated based on national averages (default values), the CBAM would end up treating producers the same regardless of their efforts to reduce their climate impact by using onsite or offsite renewable energy as a production input. Indeed, producers of goods covered by the CBAM would pay twice. Once for the renewable energy they may be contracting to purchase and a second time for emissions based on national averages (default values) for which they are not accountable due to their explicit procurement of renewable energy. This will undermine the motivation for producers outside of the EU to proactively use, and invest in, renewable energy. Treating all commodity producers identically by using default values, irrespective of their efforts to reduce the emissions related to their production processes reduces the incentive to invest in low-carbon technologies in their home countries. This would weaken the ongoing transition to carbon-free commodity production and the development of low-carbon technologies. It would also increase global CO2 emissions by reducing the demand, and revenue, for locally produced renewables and low-carbon technologies. This opportunity cost will also affect European companies with production or suppliers outside of Europe, reducing their incentives to run extra-European facilities on renewable energy. The best way to encourage these commodity producers to purchase more renewable energy or low-carbon technologies is to require them to substantiate their products actual embedded emissions based on contractually defined emission rights such as energy attribute certificates (EACs), combined with (or without) PPAs. Making use of these internationally recognized and implemented certification standards will allow for clarity as to the use of renewable electricity. EACs form the backbone of attribute ownership, not only in Europe and the United States but in nearly every global jurisdiction where you can contract or procure renewable power. The issuance, ownership, and cancellation of tradable EACs provide the proof that emissions are related to a given product. In Europe this system is known as the Guarantee of Origin (GO or GoOs), in other jurisdictions as Renewable Energy Certificates (RECs) but they are all EACs energy attribute certificates. In fact, most global EAC systems are local or regional adoptions of the system of GOs first designed by the EU more than 25-years ago. **Due to character limits, our full response is provided in the attached file**
Read full response14 Aug 2025
Call for Evidence for an Impact Assessment Carbon Border Adjustment Mechanism (CBAM) downstream extension, anti-circumvention, and rules on electricity emissions The International Tracking Standard Foundation (I-TRACK Foundation) welcomes the adoption of the European Commissions Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) in May 2023. Pulling together this world-first legislation is a complex and commendable feat, and we fully support the Commissions intent to both protect the European economy and industry from carbon leakage and to accelerate the decarbonisation of global supply chains. Protecting European industry from carbon leakage while pushing for more renewable energy and carbon pricing in Europes trading partners provides simultaneous protection for European value chains and provides incentives to make them more sustainable. Pricing embedded carbon strengthens the case for Clean Trade and Investment Partnerships under the Clean Industrial Deal and grants European industry better access to more sustainable materials in often complex value chains. However, as currently proposed, the CBAM threatens the goal of encouraging local renewable energy use in non-European countries. If a CBAM adherent products embedded emissions are calculated based on national averages (default values), the CBAM would end up treating producers the same regardless of their efforts to reduce their climate impact by using onsite or offsite renewable energy as a production input. Indeed, producers of goods covered by the CBAM would pay twice. Once for the renewable energy they contract to purchase and a second time for emissions based on national averages (default values) for which they are not accountable due to their explicit procurement of renewable energy. This will undermine the motivation for producers outside of the EU to proactively use, and invest in, renewable energy. Treating all commodity producers identically by using default values, irrespective of their efforts to reduce the emissions related to their production processes, reduces the incentive to invest in low-carbon technologies in their home countries. In addition, it entails exporting this investment from local low-carbon technologies to the European market in the form of mandatory CBAM certificates. In this way, the payment for CBAM certificates constitutes an opportunity cost that could have been invested locally in low-carbon solutions like renewable electricity. This would weaken the ongoing transition to carbon-free commodity production and the development of low-carbon technologies. It would also increase global CO2 emissions by reducing the demand, and revenue, for locally produced renewables and low-carbon technologies. This opportunity cost will also affect European companies with production or suppliers outside of Europe, reducing their incentives to run extra-European facilities on renewable energy. The best way to encourage these commodity producers to purchase more renewable energy or low-carbon technologies is to require them to substantiate their products actual embedded emissions based on contractually defined emission rights such as energy attribute certificates (EACs). Making use of these internationally recognized and implemented certification standards will allow for clarity as to the use of renewable electricity, CCUS, renewable gases, and other decarbonizing technologies. **Due to character limits, our full response is provided in the attached file**
Read full responseResponse to Carbon footprint methodology for electric vehicle batteries
28 May 2024
Feedback to the Commission draft delegated Regulation supplementing Regulation (EU) 2023/1542 on estimating lifetime carbon footprint of batteries for EVs. Clear rules for estimating and communicating the lifecycle carbon intensity of batteries are necessary to allow companies to communicate their sustainability efforts and climate impact transparently, reliably and uniformly in the single market. However, these rules should allow for forward-leaning companies to out-perform their less sustainably minded competitors, be in line with other EU standards for claiming renewable electricity consumption and recognise national and global frameworks for tracking and claiming renewable energy within markets. Contradictory approaches to assessing and communicating environmental footprints will undermine public confidence in environmental reporting. They increase the administrative burden, and therefore costs, of data collection and reporting on companies, and they make it more complicated for investors to find companies with sustainable business models. The Commissions proposal threatens to undermine the harmonised European approach to estimating carbon intensity of electricity and related products, as the proposal deviates from established European principles for claiming consumption of renewable energy, limits individual agency for forward-leaning companies, and ignores stringent global systems to track, allocate and verify production of renewable electricity. We point especially to the principles outlined in the European Sustainability Reporting Standards (under the CSRD), to Commission Delegated Regulation (EU) 2023/1184 on claiming renewable electricity consumption towards hydrogen, and to the requirements of the RED III that energy suppliers use Guarantees of Origin (GOs) to document the contents of their energy sales. By not allowing for the use of contractual instruments, such as GOs and other global energy attribute certificates, in claiming renewable electricity used in production and charging, Regulation (EU) 2023/1542 can force companies to report different environmental footprints in their annual CSRD-reporting, in their environmental performance claims under the Green Claims Directive and in their declaration of carbon intensity under Regulation 2023/1542. Crucially, the draft delegated Regulation also acknowledges the use of GOs by not allowing for double counting of electricity from a direct connection for which the GOs have already been sold to a third party (annex to the draft delegated Regulation, point 2.4.1). Systems for verifiably tracking and allocating renewable electricity production post-hoc exist in North America (RECs) and in several countries worldwide covered by the I-REC methodology for electricity. As currently proposed, the draft Regulation risks contributing to double counting by requiring a grid-mix derived carbon intensity, which could allow companies to claim renewable electricity already accounted for through market instruments towards their own consumption, a risk that is expressly addressed for the EU and EEA member countries, and in the case of direct transmission lines (annex to the draft delegated Regulation point 2.4.1). We strongly urge the Commission to add a methodology for assessing carbon intensity that relies on reliable contractual instruments for electricity to the two existing proposed methodologies. This would be in line with other European principles for reporting electricity consumption, ensure clarity on environmental footprint reporting for final consumers and contribute further to renewable energy expansion within the EU.
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