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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.

Carbon Market Watch urges the European Commission to adopt the most ambitious options for the EU ETS aviation coverage, specifically advocating for full coverage of emissions and 100% auctioning of allowances from the regulation's adoption. The organization criticizes CORSIA as an ineffective climate strategy and warns that replacing EU ETS coverage with CORSIA would reduce climate ambition and revenue. Additionally, the document calls for the regulation of non-CO2 effects, which are estimated to multiply the global warming impact of aviation CO2 by 2-4 times.

The report evaluates the Greenhouse Gas Protocol's Land Sector and Removals Standard (LSRS), a framework for corporate accounting of land-based emissions and carbon removals. While praising the mandate for separate accounting of emissions and removals, the authors identify critical weaknesses: the voluntary nature of removals reporting and a provision that may allow the SBTi's FLAG Guidance—which permits netting—to take precedence. The analysis also criticizes the inclusion of enhanced oil and gas recovery, the lack of mandatory measurement-based quantification, and loopholes in 'physical traceability' via non-proportional mass balance. The report concludes with recommendations to make removals reporting mandatory, exclude fossil fuel recovery, and assert the LSRS's primacy over other target-setting frameworks.

The report argues that while the EU ETS has halved emissions in key sectors, it remains structurally oversupplied and hampered by free allocation subsidies. It advocates for the total elimination of free allowances, the expansion of the system to cover all international aviation and shipping, and the rejection of carbon offsets and removals. The document emphasizes that the Market Stability Reserve (MSR) must be preserved to maintain a strong carbon price signal and that revenues should be redirected from fossil fuel subsidies toward a 'people first' transition.

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.

The report by Carbon Market Watch outlines a framework for 'carbon pricing done right,' arguing that such systems must be integrated into broader policy packages and based on strict emission caps to be effective. It emphasizes the 'polluter pays principle,' warning against free allocations and offsets, which it claims can weaken price signals and lead to greenwashing. The document advocates for transparency, the reinvestment of revenues into climate action and vulnerable communities, and a cautious approach to carbon leakage and border adjustment mechanisms to avoid protectionism while ensuring climate justice.

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.

The document argues that the aviation sector has benefited from excessive exemptions under the EU ETS and that the international CORSIA scheme is an ineffective substitute. It recommends bringing international flights back under the EU ETS, phasing out free allowances to airlines, and addressing non-CO2 climate impacts to align the sector with the Paris Agreement and the polluter pays principle.

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.

The report by Carbon Market Watch provides a framework for implementing 'right' carbon pricing, arguing that such systems must be integrated into a broader policy mix, feature declining emission caps, and avoid loopholes like free allocations and carbon offsets. It emphasizes the need for transparency, the reinvestment of revenues into climate action and vulnerable communities, and the use of carbon border adjustments to prevent leakage while maintaining equity.

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.

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%.

The document asserts that there is no evidence of carbon leakage in Europe from 2005 to 2012, yet the European Commission continues to over-allocate free pollution permits. It criticizes the Commission for using an artificially high carbon price of €30 in its 2015-2019 carbon leakage list, which inflates industry costs and reduces government auctioning revenues. The briefing suggests that using a more realistic carbon price of €16.5 or €10 would significantly reduce the number of free permits and exclude sectors like cement and steel from full compensation.

The document explains the EU's 2030 climate and energy framework, focusing on the EU Emissions Trading System (EU ETS) and the Climate Action Regulation (CAR). It details the requirements for Member States to develop National Energy and Climate Plans (NECPs) and identifies 'loopholes' in the CAR that may delay climate action. The guide recommends that civil society engage in the NECP process to push for the phase-out of free emission allowances, the introduction of carbon floor prices, and the avoidance of flexibility mechanisms that undermine net-zero transitions.

A joint statement from NGOs urging the Economic and Financial Affairs Council (ECOFIN) to implement the Carbon Border Adjustment Mechanism (CBAM) as a direct alternative to EU ETS free allowances and indirect cost compensation to maintain decarbonisation incentives.

Carbon Market Watch proposes a comprehensive strengthening of the EU ETS, including increasing the Linear Reduction Factor to reach zero emissions by 2040 and increasing the Market Stability Reserve intake rate to 36% from 2024. The organization advocates for the full auctioning of emission allowances, earmarking 100% of revenues for climate action, and extending the system to include international maritime transport and waste incineration. Conversely, it argues against including road transport and buildings in the ETS and opposes the inclusion of Carbon Dioxide Removal (CDR) credits.

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.

The policy brief outlines seven areas where the EU should enhance its climate policies following the Paris agreement. Key recommendations include increasing the 2020 emission reduction target to 30%, revising the 2050 low-carbon roadmap to meet the 1.5°C objective, and adopting 5-year ambition cycles. It also calls for the phase-out of free pollution permits for industry, the inclusion of aviation and maritime sectors in the EU ETS, and the use of the Sustainable Development Mechanism to finance emission reductions in developing countries without relying on offsetting.

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'.

The paper analyzes the shift toward concrete implementation of climate-related trade measures, such as carbon border adjustment mechanisms and deforestation regulations. It details recent activities within the WTO's Committee on Trade and Environment and the outcomes of COP30, emphasizing the need for international cooperation on transparency, interoperability, and development support to avoid market fragmentation.