On Carbon Border Adjustment Measure regulation, European Aluminium recommends internationally accepted emission factors for importer reporting and exclusion of energy attribute certificates due to lack of robust uniform rules, allowing greenwashing

Sample article from our Government & Public Policy

July 14, 2023 (press release) –

This note outlines the position and European Aluminium’s proposed legislative amendments to the draft implementing regulation on reporting obligations during the transitional period for products under the scope of the Carbon Border Adjustment Measure...

We would therefore recommend during the transitional period that:

  • All importers must refer to emission factors internationally accepted such as the IEA Electricity Emission factors. Third countries’ national grid mix should be the compulsory value to be used for reporting indirect emissions in CBAM products.
  • If available and on a voluntary basis, other emission factors can be used to complement IEA electricity emission factors.
  • Use of energy attribute certificates (irrespective of their name in the 3rd country) must be explicitly and clearly excluded since there is no global robust system ensuring uniform and horizontal rules for energy attribute certificates. Allowing the use of such certificates would also facilitate institutionalized greenwashing, whereby even a facility that is directly connected to a coal plant would be able to purchase some certificates (at extremely low prices) in order to ‘prove’ that the electricity is decarbonized. The Annex must clearly reflect this exclusion.

Industry Intelligence editor's note: See the attached document in PDF fornat for the full position statement of European Aluminium.


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