Emissions
First, CBAM is based on products while the EU ETS is based on processes. However, it can be problematic to allocate emissions to the different goods produced by one installation as admitted by the European Commission (EC) because as the EC said, ‘there are no rules for going into more detail’ [1].
Secondly, the CBAM regulation only covers a limited number of greenhouse gases (GHG) [2]. Most notable, the highly potent methane is not covered. For example, for imported electricity, methane emissions from power plants are left out despite energy generation accounting for about 20% of global methane emissions [3].
Thirdly, the proposal only applies to direct emissions not imported ones [2]. This means that for products that require a lot of electricity, a significant amount of imported emissions will be missed. One example is aluminium, often referred to as ‘solid electricity because of the high amounts of electricity required [4].
Export rebates
During production, transport and sales, companies pay taxes on the goods they export. Export rebates entail the refund of such taxes [5]. Industry wants to have these for ‘products which are produced in the EU and exported to some countries which do not have the equivalent carbon limitation or pricing policies’ [6]. They are concerned that in the absence of both free allocation and export rebates, they will not be able to compete in international markets. However, there are legal challenges to this [7]. Environmental NGO’s are highly critical of this idea as well. Carbon Market Watch said: ‘Asking for export rebates on top of free allowances and CBAM is like having the cake, eating it, and reaching over for the muffins too’. Experts in the Commission informally admitted that export rebates weren’t possible [6].
LDCs
There have been arguments to make exemptions for Least Developed Countries (LDC’s) [8]. But the Commission argued they only account for 0.1% of imports of CBAM covered products. They state that exemptions could encourage them to increase emissions and they would then have to dismantle that carbon-intensive industry as any exemptions would be temporary [9]. Complimentary to that argument, the Commission declared that support for LDCs to implement CBAM will take place through relying on existing projects and initiatives including the Global Gateway[10].
Carbon pricing
Though the EU does not plan to include export rebates into the CBAM mechanism, the CBAM fee can be reduced if a carbon price has been paid in the exporting country [2, 9]. The proposal only recognizes a carbon tax or an emission trading system [11]. This is known as ‘explicit carbon pricing’ [12]. CBAM does not recognize implicit carbon pricing, the carbon cost incurred through regulations [13]. This could lead to tensions with trade partners with no explicit carbon price like the US [14].
Affected countries
Which country will be the most affected depends to some extent on the indicator you look at. The following three graphs look at imports into the EU27 in tonnes and euros and also at export shares.
Both figures 1 and 2 show Russia as the biggest exporter of CBAM covered goods to the EU among the nine countries. For China this is different. If we look at the amount in tonnes (figure 2), China is only joined 4th with the UK. In monetary value however, China is the 2nd most important country. The three other most important countries are Ukraine, Turkey and the UK. Countries like Japan, South Korea, India and the US are less important exporters. When looking at the type of goods, it is clear that iron and steel are by far the most dominating type.
Figure 1: imports of CBAM covered goods into the EU in millions of euros [15].
Figure 2: imports of CBAM covered goods into the EU in thousands of tonnes [15].
To get a more accurate picture of how much these countries will be impacted, we must compare their imports of CBAM covered goods into the EU to their total exports. This is referred to in figure 3 as their export share of CBAM covered goods. It is clear that Ukraine stands out with a share of over 7% followed by Turkey, Russia and the UK. It is perhaps not a surprise that shares are higher for neighbouring countries whilst those for countries like the US and Japan are very low.
Figure 3: export share of CBAM covered goods into the EU [15, 16, 17, 18].
Conclusion
CBAM has generated a lot of debate around various contentious issues as shown above. Industry, NGO’s, and third countries are all trying to get the best proposal for them. For the climate, the impact will likely be small given its limited scope [17]. The discussions on their own, however, are already showing a positive impact with CBAM encouraging countries to be more aware and making them ask the right questions.
