C 152/182
EN
Official Journal of the European Union
6.4.2022
1.6.
The EESC prompts the European Union to help less developed countries improve their technological capabilities, to avoid the risk of CBAM circumvention.
1.7.
A sound verification of the actual emissions embedded in imported products will be key to a fair deployment of the CBAM.
The EESC recommends that the Commission set specific requests to authorised verification bodies.
1.8.
The Committee notes the need for a strong industrial footprint in Europe which is fully competitive, and climate responsible.
1.9.
At the same time as the legislative procedure, the Commission is requested to carry out an impact study on the possible effects of the CBAM along the value chain, as a consequence of its implementation.
1.10.
The introduction of CBAM would cause a major change in the world trading system.
The EU must take all necessary steps to ensure that CBAM does not lead to an increase in GHG emissions in other parts of the world with the potential for extra global emissions.
The CBAM must not in any way lead to the deindustrialisation of the EU.
The EU must balance its climate ambition with the real fact that reducing greenhouse gas (GHG) emissions is a global issue.
1.11.
The political dimension of the CBAM has not been sufficiently highlighted.
The final decisions regarding the CBAM will largely be based not only on discussions within the EU but also on the negotiations that will be necessary with trading partners to agree on an outcome and avoid a trade conflict.
1.12.
The EESC has a reasonable expectation that a functioning CBAM system will make employment in the climate-friendly transformed former CO2-intensive companies and sectors more robust.
However, it also warns of the risk of failure of the CBAM, in conjunction with the ETS system.
The complete abolition of free allocation with the introduction of the CBAM could lead to major job losses in the EU.
1.13.
The CBAM will support both the EU climate ambition and a stronger future industrial footprint in Europe.
Obvious risks, such as difficulties in the verification of provided information about CO2 emissions from third countries and possible circumvention must be taken into account when implementing the CBAM, during and after the transition period.
2.
Gist of the Commission proposal 2.1.
On 14 July, the Commission published the ‘Fit for 55: delivering the EU’s 2030 Climate Target on the way to climate neutrality’ package (1), It includes a proposal on the Carbon Border Adjustment Mechanism (CBAM) (2), which is closely linked to the revision of the Emissions Trading System (ETS) Directive (3).
The fit for 55 package itself arises as a consequence of the European Green Deal Communication (4), which was presented on 15 December 2019.
2.2.
The proposal provides for a ‘notional ETS’ to be applied to imports of several industrial products and electricity.
The sectors covered in the first phase are: cement, steel, fertilisers, aluminium and electricity.
2.3.
For those materials with more intensive downstream processing, the proposal already includes many downstream products.
Nevertheless, there is a reference to ‘complex products’ which could enlarge the scope of the proposal.
2.4.
(1) (2) (3) (4)
The CBAM administrative burden rests with the Commission, the Member States and importers into the EU market.
COM(2021) COM(2021) COM(2021) COM(2019)
550 564 551 640
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