Use of Border Adjustment Measures
Summary
The paper examines how to equalise carbon costs between domestic and imported cement and clinker. It identifies two primary calculation requirements: the difference in carbon costs of production and the carbon intensity of imported products. The author evaluates three options for determining carbon intensity—plant-by-plant assessment, benchmarking, and default values—concluding that a system of stringent default factors with an option for plant-level evidence is the most practical compromise to balance accuracy with administrative feasibility.
Key insights
- Border Adjustment Measures (BAM) aim to reduce carbon leakage by equalising the carbon costs for products shipped between regions with and without Emissions Trading Schemes (ETS), thereby leveling the playing field for domestic producers.
- Calculating the carbon cost difference is complicated by the fact that direct ETS prices are only one element; other non-pricing climate policies in exporting countries, such as energy efficiency measures in China, India, and Japan, may also impose costs.
- Determining the carbon intensity of cement is influenced by three main factors: the clinker content in the final product, the specific energy consumption of the kiln technology, and the fuel mix used.
- Plant-by-plant assessment is the most accurate method for determining carbon intensity but is currently unworkable due to the high administrative burden and lack of a common international monitoring, reporting, and verification (MRV) framework.
- Benchmarking based on Best Available Technology (BAT) is simple to implement but risks being either too stringent, potentially violating WTO rules, or too generous, which would fail to fully equalise carbon costs.
- The author proposes a 'third way' using stringent default values (potentially based on regional clinker intensity) while allowing producers to provide plant-level evidence to prove lower emissions, which could serve as a bridge to full plant-by-plant MRV.
- The WBCSD Cement Sustainability Initiative's 'Getting the Numbers Right' (GNR) database, covering 844 installations and over 73% of Annex I production, provides a robust existing data source that could support the implementation of BAM.
Cite the original document
- APA
- Cook, G. (2011). Use of Border Adjustment Measures. Climate Strategies. https://climatestrategies.org/wp-content/uploads/2014/11/cs-border-adjustment-measures-cement-sector-perspective-cook.pdf
- Chicago
- Cook, Gregory. Use of Border Adjustment Measures. Climate Strategies, 2011. https://climatestrategies.org/wp-content/uploads/2014/11/cs-border-adjustment-measures-cement-sector-perspective-cook.pdf.
- Wikipedia
- {{cite report |last1=Cook |first1=Gregory |title=Use of Border Adjustment Measures |publisher=Climate Strategies |date=September 2011 |url=https://climatestrategies.org/wp-content/uploads/2014/11/cs-border-adjustment-measures-cement-sector-perspective-cook.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{cook2011use, author = {Cook, Gregory}, title = {{Use of Border Adjustment Measures}}, institution = {Climate Strategies}, year = {2011}, month = sep, url = {https://climatestrategies.org/wp-content/uploads/2014/11/cs-border-adjustment-measures-cement-sector-perspective-cook.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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