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The letter advocates for a CBAM that covers all high-emitting sectors and indirect emissions from the start, a faster phase-out of free ETS allowances to incentivize green investment, and the earmarking of CBAM certificate revenues for climate mitigation and adaptation in least developed countries.

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  • The authors argue that CBAM should include all high-emitting sectors and indirect emissions from the beginning to maximize environmental benefits. Specifically, they support adding hydrogen, organic chemicals, and plastics to the scope to prevent pollution shifting between materials, and call for the full inclusion of all ETS sectors by 2030.
  • The letter calls for an accelerated phase-out of free pollution permits for all ETS sectors, asserting that waiting until 2030 would undermine the effectiveness of both CBAM and the ETS. A faster phase-out is estimated to generate over €500 billion in additional revenues for green transformation and up to €160 billion for the ETS Innovation Fund by 2030.
  • The authors recommend that revenues from CBAM certificates be directed to a dedicated fund for climate mitigation and adaptation in least developed countries. They warn that allocating these funds to the EU budget could lead to World Trade Organisation legal challenges and perceptions of the mechanism as a protectionist fiscal tool.

Cite the original document

APA
Carbon Market Watch (n.d.). NGO letter for ENVI committee on CBAM vote. https://carbonmarketwatch.org/wp-content/uploads/2022/05/NGO-letter-for-ENVI-committee-on-CBAM-vote.pdf
Chicago
Carbon Market Watch. NGO letter for ENVI committee on CBAM vote. n.d. https://carbonmarketwatch.org/wp-content/uploads/2022/05/NGO-letter-for-ENVI-committee-on-CBAM-vote.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=NGO letter for ENVI committee on CBAM vote |url=https://carbonmarketwatch.org/wp-content/uploads/2022/05/NGO-letter-for-ENVI-committee-on-CBAM-vote.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatchndngo, author = {{Carbon Market Watch}}, title = {{NGO letter for ENVI committee on CBAM vote}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2022/05/NGO-letter-for-ENVI-committee-on-CBAM-vote.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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