The European Commission has published a summary of feedback on how carbon prices paid outside the EU could reduce bills under the Carbon Border Adjustment Mechanism (CBAM), a scheme that charges for the carbon emissions linked to certain imports.
The Commission said on Wednesday that it assessed 158 responses after launching three calls for evidence on 28 August 2025 to help prepare rules for the “definitive phase” of CBAM.
Most inputs came from businesses and business associations (76%), with the remainder from public authorities, NGOs and academics.
Responses were almost evenly split between EU-based stakeholders (54%) and participants from outside the EU (46%), with significant input from China, Turkey and the UK.
The most active sector was iron and steel, with 36 responses, followed by electricity, aluminium and chemicals.
Many respondents backed recognising “robust” foreign carbon pricing schemes — such as the UK Emissions Trading Scheme (UK ETS) and China’s emissions trading system — when calculating CBAM charges.
Some stakeholders argued that taxes, levies, offsets and carbon credits should also be eligible, while others said eligibility should be limited to government-mandated and verified instruments.
Rebates, proof of payment and verification
Stakeholders generally agreed that rebates or compensation linked to carbon costs should not weaken CBAM, with EU respondents tending to favour stricter limits while some third-country participants pushed for broader deductions, the Commission said.
Respondents also called for definitions to align with the EU Emissions Trading System (EU ETS), the bloc’s cap-and-trade carbon market, including clarity on how to avoid double charging.
On evidence requirements, stakeholders asked for practical, standardised documentation — such as government-issued receipts — and more digital processes to cut administration and reduce fraud risks.
Respondents also urged a clear, standard method for currency conversion, including which exchange rates to use and over what time period.
Many contributors supported internationally inclusive verification rules, including mutual recognition arrangements and accreditation linked to standards such as ISO 14064 and the Greenhouse Gas Protocol.
Some warned that limiting verification to EU-accredited bodies could create trade barriers and raise compliance costs for non-EU manufacturers.

