Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030

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Carbon Market Watch criticizes the EU ETS's free allocation of pollution permits, claiming it has generated over 25 billion euros in windfall profits and stalled industrial emissions cuts. The organization argues that the current approach fails to align with Paris climate goals and recommends a more rigorous impact assessment for the 2021-2030 carbon leakage list. Key recommendations include accounting for international climate policies (such as the Chinese and Californian ETS), focusing on direct emissions, and applying the precautionary principle to ensure only sectors at very high risk of carbon leakage receive free allowances.

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  • The historical provision of free permits under the EU ETS has led to more than 25 billion euros in windfall profits and a five-year stagnation in industrial emissions, with no evidence of actual carbon leakage occurring in previous phases.
  • Under the post-2020 EU ETS reform, heavy industry is projected to receive free pollution permits valued at up to 170 billion euros over ten years, which Carbon Market Watch argues will prevent the system from effectively decarbonising European industry.
  • The assessment of trade intensity for the carbon leakage list must incorporate international climate policy developments, specifically noting that the assumption that no other jurisdictions will implement comparable policies between 2021 and 2030 is no longer valid.
  • Carbon Market Watch recommends that the precautionary principle be applied to the carbon leakage list, meaning free allowances should be restricted to sectors at very high risk of leakage to ensure other sectors pay for their externalities.

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APA
Carbon Market Watch (n.d.). Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030. https://carbonmarketwatch.org/wp-content/uploads/2017/11/CMW-feedback-on-CL-list-inception-asssessment.pdf
Chicago
Carbon Market Watch. Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030. n.d. https://carbonmarketwatch.org/wp-content/uploads/2017/11/CMW-feedback-on-CL-list-inception-asssessment.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030 |url=https://carbonmarketwatch.org/wp-content/uploads/2017/11/CMW-feedback-on-CL-list-inception-asssessment.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2017/11/CMW-feedback-on-CL-list-inception-asssessment.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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