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Issue #12

European Commission Calls for Evidence on Key CBAM Implementing Regulations

European Commission Calls for Evidence on Key CBAM Implementing Regulations, Norway Backs CBAM Extension and Strengthened Anti-circumvention Rules, South Africa Asks for Similar CBAM Flexibilities to Those Committed for the US, China to Extend its National Carbon Trading Market.

At a Glance:

  • European Commission Calls for Evidence on Key CBAM Implementing Regulations
  • Norway Backs CBAM Extension to Downstream Products and Strengthened Anti-circumvention Rules
  • South Africa Asks for Similar CBAM Flexibilities to Those Committed for the US
  • China to Extend Carbon Trading Market by 2027 to All Major Industrial Sectors and Establish a National Cap-and-trade System by 2030

European Commission Calls for Evidence on Key CBAM Implementing Regulations

On 28 August 2025, the European Commission opened a call for evidence seeking stakeholder input on three critical implementing regulations for the CBAM ahead of its definitive regime launch on January 1, 2026.

The three key areas for input are:

  1. Emissions calculation methodology, including the determination of direct embedded emissions based on actual emissions, the determination of embedded emissions for electricity, the determination of indirect embedded emissions, and the default values for goods other than electricity, to be used when embedded emissions are not based on actual emissions.
  2. Free allocation adjustments to determine the number of certificates to be surrendered by authorised CBAM declarants
  3. Carbon price reductions

The consultation will remain open for 4 weeks until 25 September.


Norway Backs CBAM Extension to Downstream Products and Strengthened Anti-circumvention Rules

Norway submitted strong support for extending the EU CBAM to more downstream products and strengthening anti-circumvention rules. The country advocates for broad inclusion of downstream products, especially those where pricing heavily depends on CBAM-regulated materials, arguing this is critical for protecting Norway's low-emission, renewable-powered industries like aluminum, ferroalloys, and silicon during the green transition.

Norway supports ongoing efforts to close regulatory loopholes by adding process scrap and substitute materials, while calling for consistent emission standards across importers and incentives for third countries to decarbonize their energy sectors. The government warns that excluding downstream products risks production moving outside the EU, which would undermine both the mechanism's effectiveness and regional competitiveness in hard-to-abate industrial sectors.


South Africa Asks for Similar CBAM Flexibilities to Those Committed for the US

On August 21 2025, the US and EU announced a major trade framework agreement which included a commitment to work to provide additional flexibilities in the CBAM implementation.

Following this, South Africa called for such flexibilities to be extended to their country and other African countries.

We have noted with interest the recent Joint United States–European Union Framework on an Agreement on Reciprocal, Fair and Balanced Trade, in which the EU committed to "work to provide additional flexibilities in the CBAM implementation" for U.S. firms. South Africa calls on the EU to extend such flexibilities to South Africa and other African countries.


China to Extend Carbon Trading Market by 2027 to All Major Industrial Sectors and Establish a National Cap-and-trade System by 2030

China released new guidelines to accelerate its low-carbon transition and significantly expand its national carbon trading system. By 2027, the carbon market will cover all major industrial sectors and, by 2030, China aims to establish a national carbon trading market based on a cap-and-trade system with both free and paid carbon allocations.

Key measures include expanding market coverage, improving the carbon emission quota allocation system, strengthening supervision of regional pilot carbon trading schemes, and enriching trading products while broadening market participation and strengthening market supervision. China also emphasized enhancing carbon accounting and reporting capabilities, enhancing the information disclosure system, reinforcing policy and legal support, and deepening international cooperation to create a robust carbon pricing mechanism that delivers notable emission reductions across the economy.


EU CBAM: 10 Common Misconceptions Manufacturers Should Avoid

The EU CBAM transitional phase has been a crucial learning journey for many stakeholders — from importers and non-EU manufacturers to public authorities. However, it has also brought its fair share of misunderstandings about how the mechanism actually works. We've published a blog post diving into 10 common misconceptions among manufacturers—breaking them down to help them avoid costly mistakes.