In the absence of equivalent measures taken by other regions of the world regarding carbon pricing, the Carbon Border Adjustment Mechanism (CBAM) is one of the possible options to protect EU industries against the risk of carbon leakage. In this respect, CBAM deserves to be carefully examined.
However, FEVE is of the opinion that, at this stage, it is extremely difficult and somehow premature to answer some precise questions without knowing exactly how CBAM will be organised. Some options proposed in the consultation (e.g. choosing between the 4 different types of CBAM as proposed by the Commission) may feel attractive under certain circumstances (e.g. co-existence of free allocation, support to exports, etc.), but can raise serious concerns if those circumstances are modified.
With this in mind, FEVE has decided to answer only those questions from the consultation which are unambiguous, leaving the others blank.
Please see here the contribution of FEVE to the October 2020 European Commission Consultation.