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Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030
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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Document type: Statement
CMW’s position on the Carbon Border Adjustment Mechanism
Carbon Market Watch argues that the Carbon Border Adjustment Mechanism (CBAM) must be implemented as a full alternative to free emission allowances to avoid market failures and incentivize industrial decarbonisation. The organization demands that the CBAM's scope be expanded to include bulk chemicals and indirect emissions, and that it provide special exemptions or support for Least Developed Countries (LDCs) and Small Island Developing States (SIDS). Furthermore, it advocates for the full earmarking of CBAM and EU ETS revenues for climate action, both within the EU and as international climate finance, while opposing the introduction of export rebates for EU companies.
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Document type: Statement
Decarbonising Europeʼs energy intensive industries
The report argues that deep decarbonisation of EU energy-intensive industries requires a combination of process innovations, product shifts, and business model transformations. For chemicals, this involves transitioning to bio-based feedstocks and enhanced plastics recycling. In steel, the HIsarna process and a shift toward electric arc furnace (EAF) production from scrap are highlighted. For cement, the report emphasizes calcium looping carbon capture and storage (CCS) and clinker substitution. It concludes that public policy, specifically the EU ETS Innovation Fund, is essential to bridge the gap between demonstration and commercialisation of these technologies by 2030.
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Document type: Report
Open letter to ITRE committee: time to vote for an EU Emissions Trading System (ETS) that works for climate and industrial transformation
Carbon Market Watch and several partner organisations call for the immediate phase-out of free EU ETS allowances, arguing they create market failures and hinder industrial transformation. The letter advocates for full auctioning of allowances to generate revenues for green investments, the removal of free allocations for sectors covered by the Carbon Border Adjustment Mechanism (CBAM), and the rejection of a Carbon Leakage Protection Reserve. It further proposes increasing the minimum annual benchmark reduction rate to 1% and integrating carbon pricing into a broader regulatory framework including pollution performance standards and green public procurement.
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Document type: Statement
Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision
Carbon Market Watch calls for the revision of the Industrial Emissions Directive (IED) to address a gap in greenhouse gas (GHG) regulation. The organization argues that the EU Emission Trading System (ETS) has failed to provide sufficient incentives for industrial decarbonisation due to the over-allocation of free allowances, which led to windfall profits of over €25 billion between 2008 and 2015. To align the IED with the European Green Deal's zero-pollution and climate neutrality goals, the author recommends deleting Article 9(1) to allow GHG emission limits in permits, making energy efficiency standards binding under Article 9(2), phasing out coal and lignite by 2030, and introducing a Paris Agreement compliance test for new industrial investments.
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Document type: Statement
Joint NGO statement on the Carbon Border Adjustment Mechanism
A joint NGO statement arguing that the EU's Carbon Border Adjustment Mechanism (CBAM) must remove the overlap with free ETS allowances, expand its sectoral scope, provide special considerations for vulnerable nations, and redirect all revenues to international climate finance to avoid being a 'protectionist' measure.
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Document type: Statement
Open letter to Members of the European Parliament: time to vote for an EU Emissions Trading System (ETS) and a Carbon Border Adjustment Mechanism (CBAM) that work for the climate and support industrial transformation
An open letter from various environmental and industrial organisations calling for a 68% reduction in ETS emissions, the phase-out of free allowances by 2030, and the use of CBAM as a replacement for carbon leakage protections to ensure the 'polluters pay' principle is upheld.
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Document type: Statement
Open letter: Time to agree on an EU Emissions Trading System (ETS) and a Carbon Border Adjustment Mechanism (CBAM) that work for the climate and support industrial transformation
The document argues that the EU Emissions Trading System (ETS) has functioned as a subsidy for high-emitting industries, providing €50 billion in windfall profits while failing to reduce emissions. The authors call for a full phase-out of free allowances by 2032, a 10% annual reduction starting in 2026, and the introduction of a fully operational Carbon Border Adjustment Mechanism (CBAM) by 2026. They further propose making any remaining free allowances conditional on energy efficiency and decarbonisation plans, and revising benchmarks to include a minimum improvement rate of at least 0.4%.
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Document type: Statement
NGO letter for ENVI committee on CBAM vote
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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Document type: Statement
The energy-intensive industry lobby and the EU ETS
The briefing argues that energy-intensive industry lobbies in the EU use 'discourses of climate delay' to protect their financial interests, specifically by securing free emission allowances. While these sectors publicly support 2050 climate neutrality, the document claims they actively oppose short-term EU ETS reforms, such as increasing the Linear Reduction Factor or phasing out free allocations. The author asserts that the industry's narrative regarding 'carbon leakage' lacks empirical evidence and serves as a justification for windfall profits. The briefing further details how technical factors in the free allocation formula (BM, HAL, CLEF, and CSCF) are manipulated by lobbyists to maintain high levels of free permits, thereby undermining the 'polluter pays' principle and delaying industrial decarbonisation.
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Document type: Briefing
O N E U K A L L O W A N C E the future of uK Carbon Pricing
Sandbag argues that a standalone UK ETS would be dysfunctional due to its small size and vulnerability to volatility and speculation. The organization recommends that the UK either remain part of the EU ETS or implement a carbon tax with a floor based on the average EU ETS price. Key proposals include expanding carbon pricing to fossil gas and fugitive methane, ending the zero-emissions treatment of large-scale biomass burning, and distributing carbon revenues to citizens as a 'climate dividend'.
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Document type: Report
ENERGY LEADERSHIP IN A TIME OF NEED: A BLUEPRINT FOR STATES
The document argues that U.S. states should implement 'no-regrets' actions in building and industrial efficiency to counter the negative economic impacts of the One Big Beautiful Bill Act (OBBBA), which is projected to cost households $170 billion in higher energy bills and reduce GDP by $1.1 trillion by 2035. It advocates for the deployment of heat pumps and electric boilers, noting that residential heat pumps have held a 56 percent market share for space heating since 2021. The briefing specifically highlights the potential of industrial electric heat pumps for low-temperature heat (under 200 °C), which are two to four times more efficient than fossil-fueled versions but currently make up less than 2 percent of the market. To overcome barriers such as upfront capital and high electricity rates, the document recommends a suite of policy actions, including adopting modern energy codes, implementing building performance standards, providing point-of-sale rebates, and creating revolving loan funds.
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Document type: Briefing
RENEWABLE ENERGY PARKS: AN ECONOMIC DEVELOPMENT STRATEGY FOR PUEBLO, COLORADO
The report advocates for the creation of a 'Comanche Energy Park' in Pueblo, Colorado, to replace the retiring Comanche coal plant by 2031. This strategy involves a diversified portfolio of wind, solar, and battery storage paired with 'flexible' industrial technologies like thermal batteries and hydrogen electrolyzers. The goal is to provide a reliable, clean electricity supply while stimulating local economic growth and maintaining property tax revenues without placing the full financial burden on Xcel Energy customers.
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Document type: Report
ENERGY LEADERSHIP IN A TIME OF NEED: A BLUEPRINT FOR STATES
The document argues that states can lead the energy transition by attracting clean industrial projects and supporting the electrification of industrial process heat. It highlights the economic risks of the federal OBBBA—projecting $170 billion in higher energy bills and a $1.1 trillion GDP shrink by 2035—and proposes specific state-level policy actions, such as clean heat production tax credits, streamlined permitting for industrial parks, and targeted support for clean hydrogen in heavy industry.
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Document type: Policy brief
Chinese Version 中文翻译--Draft 2 - China Briefing Draft - 18/06/26
China leads the world in planned utility-scale solar and wind capacity, with over 500GW already under construction. However, the transition has shifted from a 'capacity race' to a 'system integration' phase, where transmission bottlenecks and a continued reliance on coal-fired power for grid stability lead to increasing curtailment, particularly in the northwest and northern regions. While green hydrogen and local consumption offer paths for industrial decarbonization, there is a risk that these technologies may be used to justify the continued expansion of coal-based chemical industries.
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Document type: Briefing
Le Cadre économique indopacifique pour la prospérité : une nouvelle approche du commerce et de l’engagement économique
The Indo-Pacific Economic Framework for Prosperity (IPEF) is a flexible economic initiative involving the United States and 13 other nations, organized around four pillars: connected, resilient, clean, and fair economies. Unlike traditional free trade agreements, IPEF avoids tariff liberalization, which has led to criticisms regarding the lack of U.S. concessions and concerns over the long-term commitment of partners like India. Early ministerial meetings have highlighted tensions over the adoption of high standards, with countries such as Malaysia and Japan requesting transition periods, while the U.S. focuses on digital standards and industrial decarbonization as key areas of influence.
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Document type: Briefing
Clean Economy Graphics Data Sources and Documentation Overview
The document outlines the technical framework for RMI's State Clean Energy Eco graphics, which project the scale of energy transformation required for the US to reach net zero emissions by 2050. It details the use of the Princeton Net Zero America (NZA) project as the primary data source, supplemented by the Energy Policy Simulator (EPS), NREL Cambium scenarios, and population projections. The methodology covers specific metrics across electricity, industry, transportation, buildings, and human impact, including a detailed approach for downscaling potential federal investments from the Inflation Reduction Act (IRA) to the state level. To account for uncertainty in 2050 projections, metrics are generally rounded to one significant figure.
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Document type: Guide
Reinventing Fire Industry Sector Methodology
The Reinventing Fire industry model uses a stock-flow framework and EIA Annual Energy Outlook 2010 data to simulate the adoption of energy-saving measures in the U.S. industrial sector from 2010 to 2050. It tracks energy consumption, fuel expenditures, and capital investment across various manufacturing and non-manufacturing industries. The model incorporates efficient technologies, combined heat and power (CHP), waste-heat-to-electricity, and integrative design for machine drives, while accounting for refining transformations as demand shifts toward biofuels and hydrogen.
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Document type: Guide
Microsoft Word - Indonesia NDC note_final.docx
The document outlines the role of business in achieving Indonesia's 2035 NDC, highlighting a USD 3.8 trillion investment opportunity. It identifies critical barriers such as regulatory uncertainty and fragmented institutional responsibilities, while proposing solutions across the power, industry, and transport sectors to align national policy with private sector readiness.
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Document type: Briefing
Microsoft Word - JCI and WMBC 2025 - Japan NDC note_English.docx
The document analyzes Japan's second NDC, submitted in February 2025, which targets greenhouse gas emission reductions of 60% by 2035 and 73% by 2040 relative to 2013 levels. The authors argue these targets are insufficient for a developed nation and fall below the global average required for the 1.5°C goal. The briefing emphasizes that Japan is currently off track for its 2030 goals and risks economic disadvantage by maintaining a reliance on fossil fuels. It calls for a rapid phase-out of coal by 2035, a significant increase in renewable energy capacity—potentially reaching 65-80% of electricity supply by 2035—and the implementation of a robust carbon pricing system via the GX-ETS with a binding emissions cap. The report also highlights the role of electrification, particularly through heat pumps and electric vehicles, and the strong support for more ambitious action from the Japanese business community.
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Document type: Briefing