Summary of stakeholder responses to the public consultation for a border carbon adjustment in the EU

Date: 25 November 2020

Author(s): Andrei Marcu, Dariusz Dybka and Alexandra Maratou


The European Commission published a questionnaire on a Carbon Border Adjustment Mechanism (CBAM) for the public consultation that took place between July 22 and October 28 2020.

The objective of this paper is to highlight and summarize key points raised in the submissions responding to the latest public consultation, capturing the differences, commonalities and general trends, in order to provide the reader with a concise overview of stakeholders’ positions on CBAM for the EU. This paper is limited to the over 20 submissions that were made available to ERCST by some of the stakeholders that made submissions. An overview of the submissions covered, highlighting the key points made, is presented in alphabetical order in a summary table.

The outcome of the consultations can be grouped in the following main categories regarding the design of the mechanism: Preferred option; Scope and pilot phase; Carbon leakage and free allowances; Calculation of carbon content; Impacts & circumvention; WTO aspects; and Alternatives.

Given the limited number of submissions considered for this paper, the official summary by the European Commission may be different.