WRITTEN COMMENTS ON THE DRAFT CARBON TAX BILL, 2017

The Centre for Environmental Rights (CER) and Greenpeace Africa submitted joint comments on the Draft Carbon Tax Bill, 2017, arguing that the proposed tax rate and extensive allowances are insufficient to incentivize a transition to energy efficiency or meaningfully reduce South Africa's greenhouse gas (GHG) emissions.

• The proposed carbon tax rate of R120 per ton of carbon dioxide equivalent (CO2e) is considered outdated and too low to change the behavior of emitters or reflect the true environmental and health costs of emissions.
• To align with the High-Level Commission on Carbon Prices' conclusions based on the Paris Agreement, the carbon tax rate in South Africa would need to be R473 per ton of CO2e by 2020.
• The Bill's use of tax-free thresholds and allowances—including a 60% basic tax-free allowance and transitional allowances capped at 95%—could result in an effective tax rate as low as R6 to R48 per ton of CO2e, potentially allowing large emitters to treat the tax as a simple expenditure rather than a catalyst for change.
• The authors express concern that allowances for industrial process emissions and fossil fuel combustion will limit the tax exposure of South Africa's largest emitters, Eskom and Sasol, thereby decreasing the tax's overall effectiveness.
• The submission strongly opposes clause 13 of the Bill regarding offset allowances, stating that offsets allow emitters to continue emitting indefinitely and contradict the goal of behavioral change in carbon-intensive industries.
• South Africa is identified as the leading CO2 emitter in Africa, contributing approximately 1.5% of global GHG emissions and ranking among the top 20 highest emitters globally.

APA

Centre for Environmental Rights (2018). WRITTEN COMMENTS ON THE DRAFT CARBON TAX BILL, 2017. https://cer.org.za/wp-content/uploads/2018/04/CER_GP-Submission-on-Carbon-Tax-Bill-2017-29.03.2018.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN COMMENTS ON THE DRAFT CARBON TAX BILL, 2017. 2018. https://cer.org.za/wp-content/uploads/2018/04/CER_GP-Submission-on-Carbon-Tax-Bill-2017-29.03.2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN COMMENTS ON THE DRAFT CARBON TAX BILL, 2017 |date=29 March 2018 |url=https://cer.org.za/wp-content/uploads/2018/04/CER_GP-Submission-on-Carbon-Tax-Bill-2017-29.03.2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN COMMENTS ON THE DRAFT CARBON TAX BILL, 2017}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = mar, url = {https://cer.org.za/wp-content/uploads/2018/04/CER_GP-Submission-on-Carbon-Tax-Bill-2017-29.03.2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }