- Client: European Commission
- Implementation period: May, 2024 - September, 2025 (Completed)
- Geographic coverage: European Union
- Theme: Carbon Pricing, Climate Agreements and Policies, Climate Change
- Topic: Carbon Border Adjustment Mechanism (CBAM), Carbon leakage, Carbon Pricing
- Experts: Long Lam, Tatiana Cuervo Blanco, Nora Cheikh, Perla Torres, Andrea Finesso, Aurora Miari, Anya Al-Salem, Private: Liza Leimane, Private: Ajla Kospo
The aim of this study is to support the Commission in identifying products further down the value chain of the goods listed in Annex I to which the CBAM should potentially also apply as per Article 30(3) of the CBAM Regulation, and in developing the necessary requirements and rules to extend CBAM to these downstream products. Together with Technopolis Germany, Environment Agency Austria and Intellera Consulting, we led this study to supported the European Commission in identifying downstream products to potentially include under the CBAM to mitigate the carbon leakage risk of downstream products produced in the EU that face increased upstream carbon costs due to the ETS and/or the CBAM, as well as the risk of importers circumventing the CBAM on the upstream goods listed in Annex I by importing products downstream of these Annex I goods instead. The study supported the Commission in identifying at-risk downstream sectors and products, developing rules for calculating, monitoring, and reporting embedded emissions, and evaluating the compliance costs and administrative burden of a potential scope extension. In addition, the team supported the Commission in analysing the responses from the Open Public Consultation held on the potential CBAM extension.
