The EU Commission has launched a public consultation on an initiative entitled “Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions”.
According to the Commission, this initiative aims to extend the carbon border adjustment mechanism CBAM to certain downstream products in order to reduce the risk of CO2 emissions being shifted when downstream producers relocate their production abroad or EU customers switch to imports from third countries: “Additional anti-circumvention measures would target practices to avoid the CBAM financial obligation without due cause or economic justification.” The Commission also has concerns about the rules on default values and the criteria for using actual electricity-related emissions for estimation purposes, which are also covered by the initiative.
Conclusion: Despite the provisional political agreement on the Commission's proposal to simplify and strengthen the CBAM (trade-e-bility reported: Agreement on CBAM simplification), the same agreement now paves the way for the extension of the CBAM to downstream products. Affected companies should therefore continue to monitor the issue closely.
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Questions about CBAM? The trade-e-bility consulting team is available at +49/40/750687-300 or send us an email.