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EU seeks views on CBAM benchmarks, embedded emissions

  • Market: Coking coal, Electricity, Emissions, Fertilizers, Hydrogen, Metals
  • 29/08/25

The European Commission has launched a call for evidence to gather feedback on how obligations under the EU carbon border adjustment mechanism (CBAM) should account for any carbon price already paid on imported goods, the determination of CBAM benchmarks and the methodologies for calculating products' embedded emissions.

The feedback will inform the commission's development of three implementing acts. One will determine how EU importers apply for a reduction in their CBAM compliance obligations to adjust for a carbon price already paid on the given goods in a non-EU country. The act will set out rules for converting this carbon price into a "corresponding number of CBAM certificates", including evidence needed to prove the price already paid.

Another implementing act will set out the methodology for calculating free EU emissions trading system (ETS) allowance allocations embedded in products, which will then be applied as a CBAM obligation discount.

It will also elaborate the benchmarks for CBAM-covered goods, which will be derived from the existing EU ETS benchmarks used to calculate free allocations. This includes ensuring that the EU ETS benchmarks, which are designed for installations and production processes, match up with individual CBAM goods.

The approach should be simple enough to avoid a disproportionate administrative burden while maintaining accuracy, the commission said.

A third implementing act will set out the methodology to be used once CBAM's definitive period starts on 1 January 2026 to determine direct embedded emissions in imported goods based on actual emissions, embedded emissions for electricity, indirect embedded emissions and the default values for goods other than electricity used when embedded emissions are not based on actual emissions.

The feedback period runs until 25 September. The commission plans to adopt the implementing acts in the fourth quarter of this year.


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