Sandbag

We are a think tank conducting data-driven and evidence-based advocacy to improve EU climate policy.

[Sandbag @sandbag_eu]

👇 Sandbag analysis cited in the Impact Assessment:

Strengthening the CBAM by default — feedback on downstream extension, anti-circumvention and electricity emissions rules
🔗https://t.co/xQmpaouszU

5/5

[Sandbag @sandbag_eu]

The European Commission’s CBAM Impact Assessment (17 Dec) shows that circumvention risks are now being taken seriously.

The assessment explicitly recognises risks of avoidance, including via metal scrap—concerns Sandbag has consistently raised over the past year.

1/5

[Sandbag @sandbag_eu]

⚠️Proposed coercive actions could protect against carbon leakage but would add bureaucracy.

🔄An opt-out from actual data reporting should be available for trade partners, with default value mark-ups dropped—if all imports from a country use those values

4/5

[Sandbag @sandbag_eu]

Free allocation will be phased out under the EU ETS — regardless of CBAM. A better safeguard would be extending CBAM to agricultural products grown using nitrogen fertilisers, covering only the embedded emissions.

👇 Open letter from the French PM
https://t.co/XDNJpE8K63

4/4

[Sandbag @sandbag_eu]

🇫🇷 France is calling for fertilisers to be exempted from the EU’s Carbon Border Adjustment Mechanism (CBAM). The French Prime Minister has published an open letter to farmers raising concerns about fertiliser costs.

Our analysis shows this would be the wrong approach.

1/4

[Sandbag @sandbag_eu]

But CBAM is phased in gradually alongside free allocation under the EU ETS.
As a result, the price increase should only be around:
• 2026: +€2.4/t (+0.4%)
• 2027: +€4.8/t (+0.8%)

🔍 Ammonia is only one input — so impacts on most fertilisers are even lower.

3/4

[Sandbag @sandbag_eu]

🔗 Read our recent policy brief on chemicals in the CBAM:
https://t.co/ndzY4y0xYG

📄 Read the European Commission’s CBAM review report:
https://t.co/VHce8Un4Rd

#CBAM #EUETS #ClimatePolicy #Chemicals

4/4

[Sandbag @sandbag_eu]

🧭 CBAM horizontal scope expansion — encouraging signs, but why the delay?

The European Commission’s CBAM review sets out its approach to horizontal expansion, potentially covering chemicals, refinery products, pulp & paper, glass, ceramics and ferro-alloys.

#CBAM #ClimatePolicy

1/4

[Sandbag @sandbag_eu]

🏗️ The door is also open to refinery products, with the report noting that challenges “do not appear insurmountable” for these key precursors.

📆 However, despite these positive signals, the Commission will only assess whether to propose CBAM expansion in 2027.

3/4

[Sandbag @sandbag_eu]

🔍 Often overlooked

CBAM is not a one-way flow to the EU.
Where EU price pass-through is effective, exporters can gain more than they pay. These revenues can support clean industrial growth.

👇Research note:
https://t.co/20QwpuJcdS

4/4

[Sandbag @sandbag_eu]

🌍 The CBAM dividend for Ghana and Namibia

CBAM is often seen as a threat to developing-country exporters. New case studies of Ghana and Namibia suggest the opposite: EU price effects linked to CBAM can outweigh CBAM costs, turning the mechanism into a net gain.

1/4

[Sandbag @sandbag_eu]

🇬🇭 Ghana

Aluminium exports already generate a net gain of ~€4m/year.

If additional output were exported to the EU, EU price pass-through (~€156m) would outweigh CBAM fees (~€74m), delivering a net gain of ~€82m/year, even without deeper decarbonisation.

3/4

[Sandbag @sandbag_eu]

Sandbag proposed applying default values without mark-ups in circumvention cases to simplify compliance. Instead, the Commission opts for more controls, reporting requirements, and continued mark-ups — increasing complexity.
🔗Read our CBAM proposal https://t.co/xQmpaotUKm

4/4

[Sandbag @sandbag_eu]

To replace free allocation under the EU ETS, CBAM must prevent circumvention.

The Commission’s new implementation package strengthens CBAM in this respect — but in a largely bureaucratic way.

1/4

[Sandbag @sandbag_eu]

The package also addresses the so-called “scrap loophole”, first identified by Sandbag, by adding pre-consumer steel and aluminium scrap to CBAM.

This only partly closes the gap, as post-consumer scrap still plays a role.

3/4