The Carbon Border Adjustment Mechanism (CBAM), proposed by the EU Commission in April 2020, is a border tax designed to ensure that the price of imported products reflects carbon prices in Europe. It would therefore serve as a tool to incentivize increased climate ambition outside the EU, while protecting European industry from carbon leakage. The EU Commission’s inception impact assessment report stated that the CBAM would operate alongside the EU Emissions Trading System (EU ETS) as an alternative to the allocation of free emission permits, covering the cement, iron and steel, aluminium, fertilizers and electricity sectors. A public consultation was launched to gather stakeholder views in March 2020.
Following intense negative engagement from heavy industry sectors, the EU’s Carbon Border Adjustment Mechanism (CBAM) incorporated a slower phase out of the free allocation of EU Emissions Trading Scheme (ETS) emissions allowances alongside the CBAM implementation than proposed by the EU Commission. Hydrogen, steel, iron and cement were included - but not chemicals.
Carbon Tax
Inactive: completed.
The file was approved in April 2023 and entered into force in May 2023. The transitional phase of the CBAM will start in October 2023.
European Parliament: Environment (ENVI) Committee
Rapporteur: Mohammed Chahim (Socialists and Democrats)
European Council: Environment Council
Carbon Tax
Inactive: completed.
The file was approved in April 2023 and entered into force in May 2023. The transitional phase of the CBAM will start in October 2023.
European Parliament: Environment (ENVI) Committee
Rapporteur: Mohammed Chahim (Socialists and Democrats)
European Council: Environment Council
In its 26 August submission to the public consultation on extending the EU Carbon Border Adjustment Mechanism (CBAM) to downstream products, as well as on related anti-circumvention measures and electricity rules, the Korea Iron and Steel Association (KOSA) did not support expanding the mechanism’s scope to include downstream coverage or additional anti-circumvention measures.
In a September 2025 joint statement, industry associations representing European energy-intensive industries did not support the EU 2040 emissions reductions target of 90%, stating that it is "unrealistic" in the current context and advocating for its "timely review." The European Cement Association (CEMBUREAU), the European Chemical Industry Council (Cefic), the Confederation of European Paper Industries (CEPI), the European Non-Ferrous Metals Association (Eurometaux), Euromines, and FuelsEurope advocated for international carbon credits and carbon removals to be used to meet the target, a position that is not aligned with advice from the EU's scientific advisory board. They also advocated in favor of free carbon emission allocations in the EU ETS and CBAM for both "domestic and extra-EU sales" beyond 2030.
In a 26 August consultation response, Tata Steel Nederland supported the EU Carbon Border Adjustment Mechanism (CBAM), and called it “critical against global carbon leakage”. Further, it also provided certain recommendations that would strengthen the policy by preventing circumvention by EU importers and third country producers. In a 30 September press statement, Tata Steel CEO TV Narendran said that the company is closely monitoring policy developments in the EU on CBAM. These comments are in the context of a recent consultation on the extension of CBAM to downstream products.
In a 25 September LinkedIn post, Ecocem announced the launch of the Business for CBAM Coalition, which the company co-founded with other breakthrough industry actors. The Coalition supports maintaining the ambition level of the Carbon Border Adjustment Mechanism, advocates for the immediate implementation of the EU CBAM in January 2026, and stresses the urgency of phasing out free allowances under the EU ETS to "secure the long-term competitiveness of European industry."
In a 10 July joint declaration, the French cross-sector association MEDEF and the Italian cross-sector association Confindustria advocated for a weakening of both the EU Carbon Border Adjustment Mechanism (CBAM) and the EU Emissions Trading System (ETS). Despite supporting some measures to increase the effectiveness of the CBAM, the associations advocated for including unspecified "export adjustments" and promoted a continuation of existing carbon leakage protection measures under the ETS until at least 2030, in misalignment with the EU Commission's adopted phaseout starting in 2026. In addition, MEDEF and Confindustria called for a "structural review" of the EU ETS due to its potential impacts on European international competitiveness, and called for the extension of the scope of indirect cost compensation through the scheme.
In a 19 June policy proposal, the Japan Business Federation (Keidanren) appeared to not support the EU's carbon border adjustment mechanism (EU CBAM). Emphasizing concerns around cost burdens and fair competition, it suggested that countries that have taken emission reduction measures based on the Paris Agreement should be "exempted from the application of the CBAM," and requested the EU to "not unilaterally initiate monetary charges by CBAM until a concrete agreement is reached ... consistent with WTO rules." The release of the policy proposal follows a 3 June meeting on the EU CBAM with representatives from Japan's Ministry of Economy, Trade, and Industry, according to a 26 June report in the Keidanren Times.
In a May 2025 policy paper, Airlines for Europe (A4E) emphasized cost, competitiveness and carbon leakage resulting from climate policies for aviation and advocated against the extension of the Carbon Border Adjustment Mechanism to the aviation sector. A4E also appeared to advocate for the EU Emissions Trading System (ETS) to be aligned on the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) which would significantly reduce the ambition of the policy. However, it did call for a more ambitious CORSIA scheme. Finally, A4E emphasized cost, competitiveness, and carbon leakage concerns resulting from the EU SAF mandate but appeared to support it on the condition that a SAF Border Adjustment Mechanism is adopted.
In press releases published on 21 and 22 January respectively, the European Cement Association (CEMBUREAU) and the European Steel Association (Eurofer) both advocated against the delayed implementation of the EU's Carbon Border Adjustment Mechanism, as recently proposed by the European People's Party. However, both industries called for solutions in the CBAM to preserve European exports in the press releases, a position which is misaligned with the EU Commission's original policy ambition.
Ahead of the German federal election on 23 February, the Federation of German Industries (BDI) released a series of policy recommendations on climate and energy on 3 February. Among other things, the association called on the German government to only support the EU Commission's proposal to reduce GHG emissions by -90% by 2040 on the condition that the implementation of the target does not "overburden industry". The BDI also advocated for reforms of the EU Carbon Border Adjustment Mechanism, emphasizing the need to preserve exports and cautioning against a phase-out of free emissions allowances in the EU Emissions Trading System, positions that are misaligned with the EU Commission's policy ambition. Finally, the association supported 'hydrogen ready' gas infrastructure without stating the need to phase-out fossil gas, and advocated for exemptions of energy-intensive industries from EU environmental law.
Confederation of Indian Industry (CII) did not appear to support the EU Carbon Border Adjustment Mechanism in a 21 June Financial Times article. The association emphasized negative cost impacts on Indian companies and suggested the policy would impact global trading agreements.
In a joint position paper from 4 June, MEDEF and Confindustria called for a revision of the rules of the EU Carbon Border Adjustment Mechanism, including a simplification of requirements and a softening of measures on exports. In the joint statement, both industry associations also supported a simplification of the EU Emissions Trading System (ETS) implementation and additional support for industry.
In April 2024 proposals for the EU’s 2024-29 Strategic Agenda, the Spanish Confederation of Business Organizations (CEOE) advocated that competitiveness and economic growth should be placed at the center of policies. The association also appeared unsupportive of the legislated phaseout of the free allocation of emissions allowances in the EU Emissions Trading System and advocated for a technology neutral approach to the decarbonization of the mobility sector, although it supported the EU Renovation Wave.
In a December 11th meeting with the EU Commissioner Maroš Šefčovič on the clean industry transition, ArcelorMittal did not support EU state aid conditions for the steel industry to use green hydrogen to decarbonize, advocating that the industry should be able to use carbon capture and storage (CCS) or fossil gas in the short-term. The company also advocated to weaken the EU Emissions Trading System and EU Carbon Border Adjustment Mechanism, whilst supporting the Electricity Market Design reform on renewables and a range of policy to scale up demand for low-carbon steel.
According to a January 26th news release, the Japan Iron and Steel Federation appeared unsupportive of the EU Carbon Border Adjustment Mechanism (CBAM). The organization presented their concerns around the policy at a joint meeting with the China Iron and Steel Association, attended by the Director of the Metals Technology Office of the Japanese Ministry of Economy, Trade, and Industry (METI).
In comments published in a January 9th Financial Times article, Eurofer and ArcelorMittal emphasized the negative impacts of the EU Carbon Border Adjustment Mechanism on EU steelmakers. However, ArcelorMittal also supported a wider scope of the policy to include products made with a large amount of steel.
In a December 10th article from The Hindu, Tata Steel and the Confederation of Indian Industry (CII) appeared to support the EU Carbon Border Adjustment Mechanism and advocated for countermeasures to decarbonize Indian industry. Tata Steel advocated for India to introduce a base standard for carbon to aid decarbonizing the steel sector. Similarly, CII advocated for a domestic carbon levy that would see tax funds kept in India to decarbonize industry.
In a social media post on August 20th, German Chemical Industry Association (VCI) Director General Wolfgang Große Entrup strongly opposed the EU’s Carbon Border Adjustment Mechanism (CBAM), calling it "bureaucratic madness", and advocating for a moratorium on new regulations in Europe and Germany. He also emphasized the “enormous bureaucratic effort” of CBAM in an interview with a German newspaper published on the 22nd August.
The Financial Times reported on 17th August that Eurometaux supported more stringent rules and stronger penalties for importers under the EU’s Carbon Border Adjustment Mechanism (CBAM).
In a meeting with the EU Commission in March 2023, CEMEX supported the Net Zero Industry Act, but also did not seem to support elements of the Renewable Energy Directive (RED) Delegated Act on renewable hydrogen and recycled carbon fuels. It also did not support the EU Carbon Border Adjustment Mechanism (CBAM).
In a comment to the Financial Times on 7 July, Norsk Hydro CEO Hilde Merete stated that a loophole in the EU’s Carbon Border Adjustment Mechanism (CBAM) will cause greenwashing of imported products, as it incentivizes producers to “enerate as much scrap as possible which would then be remelted and exported to Europe.”
In a July 10th feedback letter to the EU Commission, the Korea International Trade Association (KITA) advocated for exceptions for third party operators, including South Korean corporates, on the EU Carbon Border Adjustment Mechanism's (CBAM) reporting obligations. KITA requested for the EU Commission to clarify that South Korean corporates could “calculate embedded emissions” based on the Korea Emissions Trading Scheme (K-ETS) methodology during the transitional period, as well as requesting for penalties to be abolished during this time. The association also requested non-EU reporting declarants to report every 6 months instead of quarterly, as EU corporates do.
As reported by a 10 July Ministry of Environment (MoE) press release, Hyundai Steel appeared to support the EU Carbon Border Adjustment Mechanism (CBAM) implementing regulation on reporting obligations with major exceptions, stating that “there are still provisions that burden companies in the process of calculating and reporting GHG emissions” and asked for the South Korean government’s active role and support on this.
In an April 24th article by SporBiz, Hyundai Steel advocated for Korean corporates to be excluded from the European Union Carbon Border Adjustment Mechanism as they are already “under the country that implements the K-ETS”.
BusinessEurope reported in its weekly newsletter that in an event at the European Union (EU) Parliament on 28th March it advocated for the EU’s Carbon Border Adjustment Mechanism to include an export rebate measure, a position which is misaligned with the EU Commission.
In a position paper on European Union (EU) industrial policy, published on 16th March, the European Steel Association (Eurofer) advocated that policymakers should reduce the regulatory burden of all policies for industry, and stated positions on a range of policies. Notably, the association advocated to include export rebates in the Carbon Border Adjustment Mechanism, a position which is misaligned with the EU Commission. Eurofer did support ambitious measures to scale up demand for green steel, but also opposed including GHG emissions standards and binding energy efficiency mandates in the Industrial Emissions Directive Reform.
In its March 2023 Steel report, the Korea Iron and Steel Association (KOSA) appeared to oppose the European Union's Carbon Border Adjustment Mechanism, stating that it would come as “a great burden to the Korean steel industry” and would “not reflect the steel industry’s carbon-neutral efforts”.
In a February 7th press release, the International Chamber of Shipping (ICS) appeared unsupportive of the EU’s Carbon Border Adjustment Mechanism, citing a report by the European Commission which revealed impacts on trade flows. ICS asserted that while shipping is not a regulated sector, the indirect impacts on ship operators may be “dramatic” as imports of products from regulated sectors will reduce.
In a social media post on 19 December 2022, the German chemical industry association Verband der Chemischen Industrie (VCI) did not support the EU Emissions Trading System (ETS) reform and Carbon Border Adjustment Mechanism (CBAM), criticizing it as a burden for the chemical industry and citing price increases as endangering the industry.
In a press release on the EU Carbon Border Adjustment Mechanism (CBAM) and EU Emissions Trading System (EU ETS) Reform trilogue agreement on 20 December, Eurometaux Director General Guy Thiran and President Evangelos Mytilineos emphasized the need to avoid deindustralization in response to the proposed CBAM and EU ETS reform.
In a December 13th tweet, German chemicals association Verband der Chemischen Industrie (VCI) criticized the EU’s carbon border adjustment mechanism (CBAM), stating it is not suitable for the chemical industry.
In several press releases in December surrounding the EU Carbon Border Adjustment Mechanism and EU Emissions Trading System Reform trilogues, Eurofer Director General Axel Eggert supported weakening the EU ETS reform and CBAM, advocating for export rebates to be included in the CBAM. He also was unsupportive of proposed measures in delegated acts in the Renewable Energy Directive Reform on carbon capture use and storage and renewable hydrogen.
In a press release on the EU Carbon Border Adjustment Mechanism (CBAM) and EU Emissions Trading System (EU ETS) Reform trilogue agreement on 16 December, CEMBUREAU broadly supported the proposed EU ETS reform, but advocated that export rebates should be included in the CBAM.
In a press release on 15 December, BusinessEurope Director General Markus J. Beyrer stressed the impacts of the Carbon Border Adjustment Mechanism and EU Emissions Trading System Reform on the competitiveness of EU industry before the policy trilogues. He also supported export rebates in the CBAM and a gradual application until the mid-2030s, and supported a slower rebasing of the EU ETS emissions cap, and advocated for the EU ETS for road transport and buildings to include private households.
As reported by Maeil Business Newspaper on the 14th December, the Korea Iron and Steel Association (KOSA) advocated for South Korea’s cost reduction from the EU Carbon Border Adjustment Mechanism (CBAM). KOSA cited the Korea Emission Trading Scheme (K-ETS) as a reason to reduce cost in the EU CBAM, but without supporting increased carbon prices for domestic Korean regulations to match international standards.
On 2nd November, the German chemicals association Verband der Chemischen Industrie (VCI) published an evaluation of the EU Green Deal. In the text the association generally supported the EU’s 2050 target, but expressed major concerns about different elements of the EU ETS reform, the Carbon Border Adjustment Mechanism, Energy Efficiency Directive and Renewable Energy Directive.
In a position paper published on 5th December, CEMBUREAU supported a weaker Carbon Border Adjustment Mechanism (CBAM) with a slower phase out of the free allocation of emissions allowances in the EU Emissions Trading System (EU ETS) reform and the inclusion of export rebates, although it did support including indirect emissions. It also was in favor of a large Innovation Fund in the EU ETS.
As reported by Financial News on the 2nd December, the Korea Iron and Steel Association (KOSA) advocated for South Korea’s exclusion from the EU Carbon Border Adjustment Mechanism (CBAM), calling it an “unfair trade barrier”. KOSA cited the Korea Emission Trading Scheme (K-ETS) as a reason to exempt Korea from the scheme, but without supporting increased carbon prices for domestic Korean regulations to match international standards.
In comments to Euractiv on 30th November in response to a study which found that industry has received almost 100 billion euros in free CO2 credits since 2013, Eurofer Director General Axel Eggert supported the maintenance of current levels of free allowances in the EU Emissions Trading System (EU ETS), a position which is misaligned from the EU Commission’s proposal for a reform of the policy. Mr Eggert stated that the steel industry needs free allocation to remain alongside the proposed Carbon Border Adjustment Mechanism (CBAM) until it is fully in place to finance new green steel projects, whilst also consistently advocating for increased government financing, for example, in May 2022.
At the November 3rd ‘Industry Conference on the EU Carbon Border Adjustment Mechanism (CBAM)’ hosted by the Ministry of Trade, Industry and Energy (MoTIE), the Korea Iron and Steel Association (KOSA) asked for support from the MoTIE to pay attention to Korean companies, and to ensure they are not discriminated against compared to EU companies under the EU CBAM.
At the November 3rd ‘Industry Conference on the EU Carbon Border Adjustment Mechanism (CBAM)’ hosted by the Ministry of Trade, Industry and Energy (MoTIE), the Korea Petrochemical Industry Association (KPIA) advocated for the Korean Emissions Trading System to be included in the EU CBAM, without a clear position on strengthening of carbon price within Korea.
On 26th October, heavy industry associations Eurofer, Eurometaux and CEMBUREAU published a joint statement on the EU’s trilogues on the EU Emissions Trading System (EU ETS) Reform and the Carbon Border Adjustment Mechanism (CBAM). The associations stated opposition to an ambitious phase out of the free allocation of emissions allowances alongside a CBAM, preferring the maintenance of full benchmark-based free allocation until the CBAM is proven effective. Failing this, they supported the EU Council’s proposed slower phase out of free allowances compared to the EU Commission proposal.
Euractiv reported on 11th October that EU policymakers had made concessions to the EU steel industry in EU Emissions Trading System (EU ETS) trilogues, agreeing that proposed reforms to tighten the benchmark against which free allowances for the industry are measured should be scrapped. Eurofer stated support for this outcome, which it has consistently advocated for since the reform proposal in 2020. Eurofer also suggested it did not support the proposal for the phase out of the free allocation of emissions allowances alongside the EU Carbon Border Adjustment Mechanism.
In a joint statement with IndustriAll on the 17th October, Eurofer advocated for public funding for industrial decarbonization projects and energy infrastructure, as well as EU regulation to support green steel markets. However, it also stated support for carbon leakage protection measures, referencing a previous statement in 2021 where the association was unsupportive of the EU Commission’s proposed Carbon Border Adjustment Mechanism and reforms to the EU Emissions Trading System.
The Federation of German Industries (BDI) published a position paper on the EU’s Fit for 55 package on 20th September, in which the association laid out its opposition to the 2035 zero emissions vehicle standard proposed by the EU Commission. In addition, the association supported quotas for low-CO2 and climate neutral aviation fuels as part of ReFuelEU Aviation, while emphasizing the risk of carbon leakage and the need for flexibility to compensate for additional costs, and called for "ambitious but realistic" quotas for biofuels in the Renewable Energy Directive (RED).
In the same position paper, BDI advocated for a Carbon Border Adjustment Mechanism (CBAM) test phase which only includes industries that support it, and the maintenance of free emissions allowances in the EU Emissions Trading System (ETS). Furthermore, the entity supported the extension of the EU ETS for road transport and buildings, but not for aviation, and it did not support “inappropriate” Minimum-Energy-Performance-Standards (MEPS) in the Energy Performance Buildings Directive (EPBD), as well as not supporting an energy consumption cap in the Energy Efficiency Directive (EED).
On 19th September, the German chemical association Verband der Chemischen Industrie (VCI) published a press release, advocating for a delay of the EU’s Carbon Border Adjustment Mechanism (CBAM) and the Industrial Emissions Directive (IED).
In a 13th September tweet, CEMBUREAU advocated for a “gradual phase out of free allocation” of emissions allowances in the EU Emissions Trading System (EU ETS) only once the Carbon Border Adjustment Mechanism (CBAM) is proven to be “watertight”, in contradiction to the EU Commission’s proposal for the files. However, the tweet stated support for the inclusion of waste incineration in the EU ETS.
In a statement on Energy Prices published on 9th September 2022, CEMBUREAU advocated to speed up renewable energy project permitting and infrastructure deployment, and was in favor of including indirect emissions in the EU’s Carbon Border Adjustment Mechanism (CBAM) to respond to high energy prices. However, it also supported extending indirect cost compensation in the EU Emissions Trading System (EU ETS) to the cement industry.
In a press release, published on 1st July 2022, Eurofer’s Director General Axel Eggert supported the EU Council’s proposal for the Carbon Border Adjustment Mechanism and the reform of the EU Emissions Trading System (EU ETS), but suggested that the proposal needed strengthened carbon leakage protection measures and export rebates. He also stated that reforms such as rebasing the emissions cap and strengthening the Market Stability Cap should be avoided.
In a report published on 28th June, Verband der Chemischen Industrie (VCI) emphasized its opposition to the Carbon Border Adjustment Mechanism (CBAM), advocating for climate clubs instead. Additionally, a Euractiv article from 22nd June reported on VCI opposing the EU Parliament's CBAM compromise, calling it a “legally uncertain bureaucratic monster prone to abuse.”
In a 27th June press release, Hydrogen Europe welcomed the European Parliament position on the EU Emission Trading Scheme (ETS). The association supported the EU ETS extension into the maritime and aviation sectors, and a new scheme for the buildings and transport sectors. It also advocated for coverage of the hydrogen sector in the system. Hydrogen Europe also appeared to support the EU Carbon Border Adjustment Mechanism (CBAM) proposal from the EU Parliament. The group supported the gradual phase out of free allowances from the EU ETS, without specifying a timeline. However, it also called for rebates for exporters by emphasizing risk of carbon leakage. Finally, CEO Jorgo Chatzimarkakis advocated for higher sectoral sub-targets and targets for renewable fuels of non-biological origin (RFNBOs) in the EU Renewable Energy Directive revision, following the EU Council’s position on the policy.
In press releases published on 22nd June, Eurofer, Eurometaux and CEMBUREAU stated positions on the EU Parliament’s proposals for a Carbon Border Adjustment Mechanism (CBAM) and reform of the EU Emissions Trading System (EU ETS). Eurometaux advocated against the inclusion of indirect emissions in the CBAM, whilst CEMBUREAU supported it. However, CEMBUREAU, Eurometaux and Eurofer all advocated for a slower phase out of the free allocation of emissions allowances in the EU ETS. Eurofer also did not support proposals to strengthen the Market Stability Reserve and to rebase the emissions cap.
In a 22nd June press release, the Verband der Chemischen Industrie (VCI) expressed its opposition to the inclusion of the chemical sector in the EU Carbon Border Adjustment Mechanism (CBAM), criticizing raising costs for CO2 certificates under the market stability reserve.
An op-ed written by the President of the EU Parliament Environment Committee, Pascal Canfin, published in Le Monde on the 2nd June reported that in a “tsunami of lobbying” Eurofer had advocated to EU parliamentarians to not support the EU Commission’s proposal to reform the EU Emissions Trading System (EU ETS) by eliminating a certain amount of carbon credits from the market, called ‘rebasing’. Canfin stated that the EU Commission had shown that without this measure, there is no chance of achieving the necessary emissions reductions in European industry to align with the UN Paris Agreement. Eurofer also appeared to advocate for the EU Parliament to support the weaker draft of the EU ETS and the Carbon Border Adjustment Mechanism (CBAM).
On 3rd June, the CEOs of energy intensive companies and industry associations, including ArcelorMittal, Holcim, Solvay, Norsk Hydro, EUROFER and FuelsEurope, signed an open letter opposing the EU Parliament Environment Committee's proposal to increase ambition of the EU's Carbon Border Adjustment Mechanism (CBAM) and the EU Emissions Trading System (ETS) reform, stressing risks of carbon leakage.
An open letter to the European Parliament and Member States facilitated by Eurofer and signed by European CEOs of EU steel companies stressed concerns regarding the recent vote in the EU Parliament Environment Committee to increase the ambition of the EU Emissions Trading System and the Carbon Border Adjustment Mechanism. They were unsupportive of "scaling back existing carbon leakage protection" and advocated for EU policymakers to "prevent a sharp decrease in free allocation." This was signed by regional and/or division CEOs of thyssenkrupp, ArcelorMittal, SSAB, Tata Steel and other companies in the steel value chain.
In a position paper published on 19th May, CEMBUREAU supported the EU Commission’s proposal for the RePower EU initiative with some exceptions. The association supported increasing electrification and renewable energy deployment through the policy, but also advocated for RePower EU to support the use of alternative waste, such as plastic waste, in cement production.
Meanwhile, in a position paper also published on the 19th May, Eurofer supported the EU Commission’s proposal for the RePower EU initiative with major exceptions. The association supported increasing hydrogen production and renewable energy deployment through the policy, but also advocated for fossil gas as a transition technology without placing conditions on carbon capture and storage. It also did not support reforms to the EU Energy Taxation Directive, including removing tax reductions for energy-intensive industries.
In a position paper published on 18th May, Cefic supported the EU Commission’s proposal for the RePower EU initiative with major exceptions. The association supported increasing low-carbon and renewable energy production through the policy, but also advocated for RePower EU to support fossil gas pipelines and more Liquified Natural Gas infrastructure.
In a position statement outlining priorities for the Spanish Presidency of the EU Council, published on 22nd May, the Confederación Española de Organizaciones Empresariales (CEOE) advocated for the EU Carbon Border Adjustment Mechanism (CBAM) to complement the free allocation of emissions allowances in the EU Emissions Trading System (EU ETS), and was in favor of an ‘adequate’ levels of free allowances.
In a position paper published on 19th May, Eurofer advocated for the continuation of current carbon leakage protection measures under the EU Emissions Trading System (EU ETS) until at least 2030, alongside the EU's Carbon Border Adjustment Mechanism (CBAM). The association also did not support proposed reforms to the EU ETS, such as strengthening the Market Stability Reserve and rebasing the emissions cap. The Director General Axel Eggert came out against the EU Parliament Environment Committee’s vote to increase the ambition of the EU ETS and the CBAM, opposing the new phaseout date of 2030.
In an 18th May press release, the Federation of German Industries (BDI) opposed the EU Parliament ENVI Committee’s position on introduction of the EU Carbon Border Adjustment Mechanism (CBAM), describing it as "an untested and abuse-prone CO2 border tariff" and advocating for continuation of free allowances under the EU ETS until "at least 2030".
In a press release on 18th May, BusinessEurope Director, General Markus J. Beyrer, stated opposition to the EU Parliament Environment Committee’s vote to increase the ambition of the EU Emissions Trading System (EU ETS) and the Carbon Border Adjustment Mechanism by speeding up the phase out of the free allocation of emissions allowances in the EU ETS. He also did not support the proposal to make free allowances conditional on decarbonization efforts.
In a press release on 23rd May, thyssenkrupp stressed that the reform of the EU Emissions Trading System (EU ETS) must not be too ambitious, in response to the EU Parliament Environment Committee’s vote to increase the ambition of the policy reform. The company was also unsupportive of the decision to speed up the phase out of the free allocation of emissions allowances alongside a Carbon Border Adjustment Mechanism (CBAM), and suggested that companies investing in decarbonization should be exempt from this phase out.
The news outlet Echodonia reported on 13th May that Cemex did not support reforms to the EU Emissions Trading System (EU ETS), stressing the costs from high carbon prices. It also advocated for a gradual reduction of the free allocation of emissions allowances in the EU ETS alongside the implementation of a Carbon Border Adjustment Mechanism (CBAM).
In a press release on 16th May, the German Chemical Industry Association (VCI) did not support reforms to the EU Emissions Trading System (EU ETS) such as the reduction of the free allocation of emissions allowances and an increase in the emissions reduction target for ETS sectors for 2030. In the same press release, VCI opposed the inclusion of the chemical industry in the EU Carbon Border Adjustment Mechanism (CBAM). In a public hearing by the German Committee for Climate Protection and Energy on 11th May, VCI did not support the CBAM, suggesting that it is protectionist and supporting the inclusion of export rebates.
In a joint statement published on 11th May, energy-intensive industry associations including Eurofer, CEMBUREAU, FuelsEurope and International Federation of Industrial Energy Consumers did not support reforms to the EU Emissions Trading System (EU ETS), including the proposal to strengthen the Market Stability Reserve and rebase the emissions cap. The associations also did not support the EU Commission’s proposed Carbon Border Adjustment Mechanism (CBAM), suggesting that the free allocation of emissions allowances in the EU Emissions Trading System (EU ETS) should be maintained until 2030.
Speaking at a conference on 12th May, ArcelorMittal Europe’s CEO and President of Eurofer, Geet Van Poelvoorde, did not support proposed reforms to the EU Emissions Trading System (EU ETS), stressing high costs and advocating for a transition phase. Van Poelvoorde also did not support the EU Commission’s proposed Carbon Border Adjustment Mechanism (CBAM), advocating to maintain the free allocation of emissions allowances until 2030. However, he supported a regulatory framework for green hydrogen.
In a 12th May statement, the European Round Table for Industry (ERT) advocated for a review of the EU Emissions Trading System and Carbon Border Adjustment Mechanism in relation to the heightened risk of carbon leakage, implying that greater carbon leakage protection may be needed which would weaken the ambition of the policies.
In a letter to the EU Parliament Environment Committee in May 2022, BusinessEurope did not support the EU Commission’s proposal for a Carbon Border Adjustment Mechanism (CBAM), suggesting that the free allocation of emissions allowances in the EU Emissions Trading System (EU ETS) should be maintained until 2030 at its current level. BusinessEurope also stated that the EU ETS reform should avoid “disproportionate cost burdens and undermining carbon leakage measures.”
In an opinion piece for Euractiv, published on the 29th April, Eurofer Director General Axel Eggert cited the war as justification for slowing down the EU Commission’s proposed phase out of free allowances in the EU Emissions Trading System (EU ETS) alongside the implementation of a Carbon Border Adjustment Mechanism. Axel Eggert also did not support proposed reforms to the EU ETS to rebase the emissions cap and strengthen the Market Stability Reserve, stressing the impacts of a unilateral and high carbon price and international competitiveness. However, Eggert also advocated for the RePowerEU and Gas and Hydrogen Decarbonisation package to increase renewable electricity and green hydrogen since the war in Ukraine “undermined the possible role of gas as a transition fuel.”
In a position paper on the RePowerEU legislation, published on 20th April, Cembureau supported a Carbon Border Adjustment Mechanism in the EU, but did not support the EU Commission’s proposed phase out of the free allocation of emissions allowances in the EU Emissions Trading System from 2026, stressing the impacts of carbon leakage. However, it did advocate for the inclusion of indirect emissions.
In a report published on 25th March, the Confederación Española de Organizaciones Empresariales (CEOE) did not seem to support the EU Carbon Border Adjustment Mechanism, stressing risks of carbon leakage and impacts on competitiveness if the free allocation of emissions allowances are phased out quickly, and advocated for export rebates.
On 24th February 2022, a range of cross-sector EU industry associations, including the European Automobile Manufacturers Association (ACEA), the European Association of Automotive Suppliers (CLEPA) and WindEurope, published a joint statement asking the EU Commission to assess the impact of the Carbon Border Adjustment Mechanism (CBAM) on downstream industries. The associations appeared not to fully support the CBAM, suggesting that it may cause carbon leakage if unspecified “necessary steps” are not taken, and appeared to support the Emissions Trading System (EU ETS) but stressed that unilateral action may also cause carbon leakage.
On the 23rd February, heavy industry associations CEMBUREAU, Eurofer and Eurometaux published a joint statement in opposition to the EU Parliament's International Trade Committee’s (INTA) proposed amendments to the Carbon Border Adjustment Mechanism.
The associations were unsupportive of the proposal to phase out the free allocation of emissions allowances in the EU Emissions Trading System (EU ETS) and advocated for the inclusion of export rebates. They also supported the continuation of indirect cost compensation in the EU ETS as a form of carbon leakage protection. Following this, on 1st March, the INTA Committee voted down an opinion on the CBAM after MEPs from the European People’s Party voted against compromise amendments they had previously supported, according to Politico.
In a webinar organized by Euractiv, the Director General of Eurofer, Axel Eggert, did not support the EU Commission’s proposal for a Carbon Border Adjustment Mechanism (CBAM) as it did not support phasing out free allocation from 2023. He also advocated for a solution for exports to be included in the CBAM.
A joint statement energy intensive industry, including the International Federation of Industrial Energy Consumers (IFIEC), CEMBUREAU, Eurofer, Eurometaux and FuelsEurope, supported the continuation of the free allcoation of emissions allowances in the EU Emissions Trading System (EU ETS) alongside a Carbon Border Adjustment Mechanism (CBAM) until at least 2030, and advocated for export rebates to be included.
In an interview with VoteWatch, a Eurofer senior executive supported a Carbon Border Adjustment Mechanism (CBAM) in the EU alongside the continuation of carbon leakage protection measures in the EU Emissions Trading System until at least 2030, and advocated for the inclusion of export rebates, a proposal which is misaligned with the EU Commission.
In January, Euractiv reported that BusinessEurope did not support the EU Parliament or EU Commission’s proposals for a Carbon Border Adjustment Mechanism (CBAM) to phase out free allocation and replacing it with a “wholly unpredictable” mode of carbon leakage protection, suggesting that the proposed timeline is rushed. However, it did support the creation of an EU-level CBAM authority.
In a joint statement in January 2022, energy intensive industries including CEMBUREAU, Eurofer and Eurometaux did not support the proposed phase out of free allocation of emissions allowances in the EU Emission Trading System alongside a carbon border adjustment mechanism, advocating for maintenance of both measures til at least 2030, and supported the inclusion of an export rebate. They also did not support proposed EU ETS reforms to reduce the free allocation of emissions allowances before 2030.
In a letter to the French presidency of the EU in January, BusinessEurope explained that it did not support the EU Commission’s proposed Carbon Border Adjustment Mechanism. It also advocated for carbon leakage protection for indirect and direct emissions and emphasised the need for “sufficient” free allocation of emission allowances in the EU Emissions Trading System. In addition, BusinessEurope stated that it did not support the proposed CO2 standards for light duty vehicles.
BusinessEurope met with the EU parliament rapporteur on the Carbon Border Adjustment Mechanism in January, and did not seem to support the EU Commission’s or rapporteur’s proposals on the policy. The association stated that a CBAM must prove its effectiveness before it can replace current carbon leakage protection measures in the EU Emissions Trading System.
On social media in January 2022 Eurofer did not support the EU Commission’s proposed Carbon Border Adjustment Mechanism and advocated for export rebates to be included in the policy, as well as for the continuation of free allocation of emissions allowances in the EU Emissions Trading System for an unspecified testing period.
Euractiv reported that Eurofer does not support the EU Parliament rapporteur for the EU Emissions Trading System reform Peter Liese’s proposal for phased out free allowances to be placed in a reserve to be distributed to industry if the Carbon Border Adjustment Mechanism (CBAM) does not prove effective. Eurofer stated that free allocation should not be reduced before the CBAM proves itself effective.
In feedback to the EU Commission in November 2021, Confindustria did not appear to support the EU Commission's proposal for a carbon border adjustment mechanism (CBAM), opposing the phase out of free allocation of emissions allowances and supporting export rebates. However, the association did support including indirect emissions in the CBAM.
In feedback to the EU Commission in November 2021, the Federation of German Industry opposed the Commission's proposal on the carbon border adjustment mechanism, describing it as "premature" and stating its position as "generally sceptical to the unilateral introduction of CBAMs", while advocating for the continuation of free allocation in 2030 and participation in the CBAM on a voluntary basis.
In a December 2021 report, the European Round Table for Industry appeared to support a carbon border adjustment mechanism with caveats, urging "realism" on the intersection between emissions trading and adjustments.
Speaking to the Financial Times, the Director General of Eurofer Axel Eggert did not support the EU Commission’s proposal for a Carbon Border Adjustment Mechanism, and opposed the phase out of the free allocation of emissions allowances in the EU Emissions Trading System. He stated that “rather than CBAM greening the EU industry, it would shrink it.”
At a conference organized by the International Emissions Trading Association a senior executive of Eurometaux advocated for carbon leakage protection measures in the EU Emissions Trading System, such as free allocation of emissions allowances, alongside a Carbon Border Adjustment Mechanism (CBAM) in the EU until 2030. It also supported excluding indirect emissions from a CBAM and the inclusion of an export rebate.
In a position paper on measures to boost competitiveness published in November 2021, the Confederación Española de Organizaciones Empresariales (CEOE) stressed that the EU’s 2050 net zero target can only be achieved while maintaining competitiveness and preserving jobs. The paper also supported the EU’s Carbon Border Adjustment Mechanism on the condition that it exclusively aims to support competitiveness and reduce the risk of carbon leakage. However, it supported the completion of Spain’s integrated railway corridors through the Trans-European Network - Transport (TEN-T) and [885318 advocated for energy efficiency investment.
The President's Council of BusinessEurope’s Paris Declaration, signed by its national federation members including Medef and Confindustria, advocated for a “smart and stable” regulatory framework which fosters industrial competitiveness and supported carbon leakage protection measures. The Council also stated support for a Carbon Border Adjustment Mechanism in the EU alongside carbon leakage protection measures in the EU Emissions Trading System for an unspecified period of time until the tool has proven its effectiveness.
EU industry associations, including the International Federation of Industrial Energy Consumers (IFIEC), FuelsEurope and Eurofer, published a joint position paper supporting the EU’s Carbon Border Adjustment Mechanism alongside the continuation of existing carbon leakage protection measures under the EU Emissions Trading System until at least 2030, and also advocated for export rebates.
BusinessEurope released a position paper on the Fit for 55 package, which advocated to maintain current carbon leakage protection measures in the EU Emissions Trading System in a transition period until 2030 alongside a Carbon Border Adjustment Mechanism, when free allocation could be reduced after the policy has been proven effective. The position paper supported some aspects of the reform to the EU ETS but with major exceptions regarding the continuation of free allowances and mechanisms to reduce the emissions cap. It also suggested that the Social Climate Action Fund would reduce funding for breakthrough technologies.
In a join position paper, Federation of German Industries (BDI), Confindustria and The Mouvement des entreprises de France (MEDEF) supported the EU's carbon border adjustment mechanism but with major exceptions, advocating for the continuation of existing carbon leakage protection measures under the EU ETS with no phase out, and also supporting export rebates.
The International Federation of Industrial Energy Consumers (IFIEC) released a position paper advocating against most of the EU Commission’s Fit for 55 proposal for reforms to the EU Emissions Trading System, and supported the Carbon Border Mechanism Proposal only as a complement to existing carbon leakage protection measures until at least 2030 and suggesting that it should include measures to compensate exporters.
Eurelectric, a European power sector trade group, stated support for reforms made to the EU’s Emissions Trading Scheme within the EU’s Fit for 55 climate package, including higher ambition and an increase in the linear reduction factor (LRF), in a reaction paper on the policy. However, the association appeared to have a mixed position on the EU’s Carbon Border Adjustment Mechanism in its reaction paper on the policy. Despite, advocating for the removal of free allocations and the inclusion of the hydrogen sector's emissions in the scope of the policy, the groups appeared to state support for exceptions for exporters.
In an interview with Handelsblatt, BASF CEO Martin Brudermüller and the President of the German Chemical Industry Association (VCI) advocated against tightening EU targets in a statement ahead of COP26, seeming to prefer a ‘climate club’ due to the impacts on competitiveness of unilateral action. The leaders also opposed a Carbon Border Adjustment Mechanism in the EU.
The Federation of German Industries (BDI) appears to have used support for a global carbon price to advocate for weaker EU regulations in a new position paper, arguing against a rapid phase-out of free emissions allowances in the EU ETS due to carbon leakage concerns. The position paper described the current EU CBAM proposal as vague but advocated for export rebates. The association also advocated for an expansion of fossil gas power in Germany alongside a doubling of renewable energy, on the basis that the fossil gas power stations should be “H2-ready”.
In a position paper published in October 2021, CEMBUREAU did not seem to support several proposed reforms to EU Emissions Trading Scheme (EU ETS) mechanisms as it stressed the risk of carbon leakage. It also advocated for the expansion of ETS credits to CCUS and waste incineration.
In another position paper also published in October 2021, CEMBUREAU advocated against the reduction or removal of existing carbon leakage protection measures in the EU Emissions Trading Scheme (EU ETS) until a carbon border adjustment mechanism (CBAM) is “fully watertight.” It also supported export rebates in the policy, but was in favor of including indirect emissions in the CBAM.
Corporate Leaders Group Europe, in a letter to the EU Competitiveness council, argued in favor of the EU Green Deal as an opportunity to make a success of the EU’s competitive sustainability, and advocated for sectoral roadmaps to guide industrial decarbonization. However, in the same letter it adopted an unclear position on the CBAM, appearing to highlight political and economic risks relating to its implementation.
In a social media post, Eurometaux supported the exclusion of indirect emissions from the EU Commission’s Carbon Border Adjustment Mechanism proposal, a position energy intensive industry had lobbied for, suggesting that EU producers would have had to pay much higher costs than non-EU producers.
In a press release this week, Eurofer advocated for a Carbon Border Adjustment Mechanism (CBAM) to be implemented alongside current carbon leakage protection measures in the EU Emission Trading System (EU ETS) until 2030. However, in a tweet from the week before the association suggested that a CBAM should complement full free allocation of emissions allowances until 2030 in the EU ETS.
A Handelsblatt article on the German election contrasted cross-party support for the EU CBAM with opposition from trade associations, quoting the Federation of German Industries (BDI) who oppose a CBAM, arguing that it is not an alternative to free allowances under the EU ETS.
ArcelorMittal has published a Climate Action Report in which it advocates for policies to decarbonize the steel sector, emphasizing the importance of government support and carbon contracts for difference, along with facilitating the production of green hydrogen. However, the report supported the EU’s Carbon Border Adjustment Mechanism as a complementary measure to EU ETS free allocation until it is fully effective and which should allow companies to pass through costs. It also supported indirect cost compensation in the EU ETS.
There has been a mixed response to the EU Carbon Border Adjustment Mechanism (CBAM) by Australian industry groups. ABC News reported on July 16th that Minerals Council of Australia CEO, Tania Constable, heavily criticized the CBAM stating that “achieving net-zero emissions requires a concerted effort on new technologies, not trade protection.” Ai Group CEO, Innes Willox, challenged the claim that the CBAM amounts to protectionism, and also appeared to support a “ramp down” in free emissions allowances under the mechanism, as reported by AFR on July 15th. In the same article, Carbon Market Institute CEO, John Connor, did not take a clear position on the CBAM, but warned of its indirect impact on Asian markets as other countries develop their own “punitive mechanisms” in response.
BDI argued that carbon leakage protections within the EU ETS should be strengthened, stating that they are non-negotiable protections. BDI also advocated that carbon border adjustment mechanisms are not an alternative to existing carbon leakage measures, and opposed ‘putting an end to the combustion engine’.
The table below lists the entities found to be most engaged with the policy. The entities are ranked by performance band. InfluenceMap tracks over 500 companies and 250 industry associations globally. Each entity name links to its full InfluenceMap profile, where the evidence of its engagement can be found.
| Influencemap Performance Band | Organization | Policy Position | Policy Engagement Intensity |
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