Carbon Market Watch’s feedback on the inception impact assessment on CBAM
Summary
Carbon Market Watch argues that a Carbon Border Adjustment Mechanism (CBAM) is preferable to the free allocation of allowances in the EU ETS, provided it is implemented without double protection. The organization recommends that CBAM cover cement, steel, chemicals, and power, and that its revenues be primarily disbursed as climate grants to developing countries. It further suggests that Least Developed Countries and Small Island Developing States be exempted from CBAM obligations to uphold the principle of common but differentiated responsibilities.
Key insights
- Carbon Market Watch asserts that neither free allocation of allowances nor a CBAM are strictly necessary for climate action because the risk of carbon leakage is unlikely to materialise, but prefers CBAM over free allocation because it ensures polluters pay for emissions.
- The organization argues that free allocation and CBAM must not co-exist to avoid double protection, and that all free allocation and cost compensation schemes under the ETS should be phased out immediately.
- To align with the principle of common but differentiated responsibilities and respective capabilities, CBAM obligations should be waived for Small Island Developing States and Least Developed Countries, and most revenues should be given as climate grants to developing countries.
- The proposed CBAM should be limited to the power, chemicals, steel, and cement sectors, as these are the highest emission sources under the ETS and their embedded imports represent approximately 8% of annual EU ETS emissions.
- The organization recommends that CBAM be implemented using the EU ETS infrastructure by requiring importers to purchase EUAs from the existing cap, rather than using a tariff measure which may be more politically difficult.
Cite the original document
- APA
- Carbon Market Watch (n.d.). Carbon Market Watch’s feedback on the inception impact assessment on CBAM. https://carbonmarketwatch.org/wp-content/uploads/2020/04/Carbon-Market-Watch’s-feedback-on-the-inception-impact-assessment-on-CBAM-1.pdf
- Chicago
- Carbon Market Watch. Carbon Market Watch’s feedback on the inception impact assessment on CBAM. n.d. https://carbonmarketwatch.org/wp-content/uploads/2020/04/Carbon-Market-Watch’s-feedback-on-the-inception-impact-assessment-on-CBAM-1.pdf.
- Wikipedia
- {{cite press release |author=Carbon Market Watch |title=Carbon Market Watch’s feedback on the inception impact assessment on CBAM |url=https://carbonmarketwatch.org/wp-content/uploads/2020/04/Carbon-Market-Watch’s-feedback-on-the-inception-impact-assessment-on-CBAM-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch’s feedback on the inception impact assessment on CBAM}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2020/04/Carbon-Market-Watch’s-feedback-on-the-inception-impact-assessment-on-CBAM-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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