Carbon Border Adjustments for Chemicals and Plastics

What was of interest at the Carbon Minds webinar for CBAM?

Here there are some key notes I took during the webinar:

  • A collaborative model developed with ETH Zürich evaluates how CBAM treats embedded emissions from chemical production outside the EU.

  • The analysis finds CBAM currently covers only 50–60% of those embedded emissions.

  • Imported ethylene or polyethylene producers pay for just over half their embedded emissions, while fully EU-based supply chains bear 100% of the carbon cost.

  • This imbalance effectively penalizes local production, creating a net negative by encouraging downstream emissions shifts or relocation of production outside the EU.

  • The coverage gap stems from excluding upstream emissions tied to fossil feedstocks (coal, natural gas, naphtha, methanol, ethane); including these would raise CBAM’s coverage to about 95%.

  • Incorporating upstream feedstock emissions is technically challenging but vital for closing the coverage gap.

  • The European Commission is assessing scope extension under the upcoming Omnibus package to integrate these upstream emissions.

  • Until CBAM achieves full value-chain inclusion, it remains ill-suited for complex sectors like chemicals, where single-product treatment misses multiple interlinked processes.

  • Current carbon leakage protection measures under CBAM are insufficiently developed to prevent emissions-intensive activities from relocating.

  • Essential operational elements are missing: a practical implementation framework that doesn’t overload administrative resources, export handling rules, and direct carbon cost compensation mechanisms.

  • Developing countries view CBAM as protectionist; their acceptance will depend on transparent, equitable, and practical implementation details.

  • Ensuring WTO compliance requires CBAM to overcome its inherently discriminatory aspects by anchoring measures clearly in environmental objectives and fair treatment.

    From my notes to the my takeaways:

  • CBAM currently captures just over half of the true carbon footprint in imported chemicals, penalizing European producers and incentivizing offshoring of emissions.

  • Bridging this gap by including upstream fossil feedstocks and embedding full value-chain coverage is technically demanding but essential to halt carbon leakage.

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European Sustainable Energy Week 2025