Proposed CBAM Amendments 1

The document analyzes proposed EU amendments to the Carbon Border Adjustment Mechanism (CBAM) intended to simplify compliance for EU importers. While the briefing notes that changes to the scope and payment timing may have minimal material impact on African exporters, it warns that modifications to 'default values' for embedded emissions and carbon pricing could negatively affect exporters. Specifically, the shift toward global averages for the most carbon-intensive countries rather than EU-specific benchmarks may increase costs for African producers lacking reliable data. The report concludes that the amendments primarily benefit EU importers and may penalize African exporters who lack the administrative capacity to provide actual installation data.

• The proposed CBAM amendments primarily aim to reduce the administrative and financial burden on EU importers through delays and scope modifications, rather than easing the burden on exporting nations.
• A new volumetric threshold of 50 cumulative tonnes per year per product is proposed to exempt smaller EU importers, but this is unlikely to significantly alter the overall economic impact on Africa since 99% of targeted emissions remain covered.
• The proposed amendments do not grant the full postponement or exemptions for African states or Least Developed Countries (LDCs) that have been advocated for; instead, they only delay the surrender of CBAM certificates from January 1, 2026, to August 31, 2027.
• Proposed changes to 'default values' for embedded emissions may penalize African exporters because importers will be allowed to choose between actual data and default values, and the latter typically estimate higher carbon values and costs.
• The EU proposes to change the reference point for countries with 'unreliable' data from the ten worst-performing EU installations to the average of the ten highest default values globally, which may remove advantages previously held by exporters treated as EU manufacturers.
• The introduction of default carbon prices to simplify deductions for domestic carbon taxes may increase costs for African exporters if EU importers choose the default over certified actual payments due to administrative ease.
• A 2023 study by the African Climate Foundation and the London School of Economics estimated that CBAM could reduce Africa's GDP by 0.91%, representing a loss of $25 billion at 2021 levels.

APA

Rumble, O., & Gilder, A. (2025). Proposed CBAM Amendments 1. African Future Policies Hub. https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035

Chicago

Rumble, Olivia, and Andrew Gilder. Proposed CBAM Amendments 1. African Future Policies Hub, 2025. https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035.

Wikipedia

{{cite report |last1=Rumble |first1=Olivia |last2=Gilder |first2=Andrew |title=Proposed CBAM Amendments 1 |publisher=African Future Policies Hub |date=14 March 2025 |url=https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{rumble2025proposed, author = {Rumble, Olivia and Gilder, Andrew}, title = {{Proposed CBAM Amendments 1}}, institution = {African Future Policies Hub}, year = {2025}, month = mar, url = {https://img1.wsimg.com/blobby/go/b2d05cc3-7b8c-4f0d-a62a-66af7434f28f/downloads/51cfbb88-de03-4494-91be-6902c5f4be09/AFPH%20Proposed%20CBAM%20Amendments%20Report%2021MAR.pdf?ver=1780902966035}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }