CMW response to public consultation on CBAM proposal

Carbon Market Watch argues that while the CBAM proposal has positive elements, such as basing certificates on verified emissions and avoiding export rebates, it requires significant revisions. Key recommendations include removing the overlap between CBAM and free emission allowances, including bulk chemicals and indirect emissions from the start, providing special considerations for least developed nations and small islands, and recycling revenues toward international climate finance rather than the Next Generation EU facility.

• The proposed crossover period starting in 2026, where CBAM and free allowances coexist for a decade, is viewed as damaging because it allows heavy industry to continue polluting past 2030 and limits the incentive for climate action outside the EU, given that over 95% of industrial emissions currently have free allowances.
• The current proposal excludes bulk chemicals (except fertilisers) and postpones decisions on indirect emissions until at least 2026; Carbon Market Watch recommends including both from the start to address plastic pollution and encourage the adoption of renewable energy and cleaner production processes.
• The EU should provide special consideration, mitigating measures, and technical, financial, and capacity support to small islands and the world's least developed nations to recognize their differentiated capabilities and right to develop.
• Allocating CBAM revenues to repay the Next Generation EU facility is considered inappropriate and potentially illegal under WTO rules; instead, a substantial portion of these funds should be directed toward international climate finance and the decarbonisation of developing countries.
• The document supports the proposal's use of actual and verified emissions, weekly certificate pricing to prevent speculation, and the exclusion of export rebates for European companies to avoid perverse incentives.

APA

Carbon Market Watch (2021). CMW response to public consultation on CBAM proposal. https://carbonmarketwatch.org/publications/cmw-response-to-public-consultation-on-cbam-proposal/

Chicago

Carbon Market Watch. CMW response to public consultation on CBAM proposal. 2021. https://carbonmarketwatch.org/publications/cmw-response-to-public-consultation-on-cbam-proposal/.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=CMW response to public consultation on CBAM proposal |date=17 November 2021 |url=https://carbonmarketwatch.org/publications/cmw-response-to-public-consultation-on-cbam-proposal/ |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2021cmw, author = {{Carbon Market Watch}}, title = {{CMW response to public consultation on CBAM proposal}}, publisher = {Carbon Market Watch}, year = {2021}, month = nov, url = {https://carbonmarketwatch.org/publications/cmw-response-to-public-consultation-on-cbam-proposal/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }