This first report under the Border Carbon Adjustments in the EU – Phase VII workstream provides ERCST’s timely and comprehensive response to the European Commission’s December 2025 Legislative Proposal.
At the launch event, ERCST presented the paper and opened the floor for feedback. The discussion centred on the Commission’s approach to exports, the planned downstream extension of the CBAM, the anti-circumvention framework, and the newly introduced Article 27a safeguard mechanism — examining the rationale behind these measures, their expected impacts, and remaining gaps in addressing identified risks.
