Summary
Cefic has submitted a response to the European Commission’s call for evidence for the implementing regulations on the methodology, CBAM certificates and the carbon price in third countries.
Key recommendations
CBAM, as currently designed, is not suitable to be extended to complex value chains such as those of organic chemicals and polymers. The four original conditions outlined in the original Cefic position are yet to be met:
- Finding a solution for exports.
- Addressing the full value chain coverage.
- Considering the indirect carbon costs related to indirect emissions.
- Guaranteeing sufficient feasibility for implementation.
In addition, the chemical sector stresses that preventing circumvention (e.g. resource shuffling, fake CO2 price, fake guarantees of origin, etc.) is also critically important and should be further improved.