The December 2025 legislative package engages with several longstanding design questions as the CBAM enters its definitive phase, including, among other topics, anti-circumvention, downstream scope extension, the treatment of third-country carbon prices, export-related leakage, and introducing a new safeguard mechanism under Article 27a.
The proposals represent an important step in the operationalization of the CBAM and an effort to make it fit for purpose, but multiple elements show unresolved trade-offs between environmental ambition, administrative feasibility, and regulatory predictability.
The credibility and effectiveness of the mechanism will depend heavily on how the forthcoming implementing acts and the upcoming ETS revision address the remaining gaps.
EU CBAM Q4 2025 Legislative Proposal 3 downloads1.48 MB
... European Roundtable on Climate Change and Sustainable Transition, available at https://ercst.org/international-credits-in-eu-cc-policy/.... read more
