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Avoiding Double Counting: Why Indirect Emissions are Likely to Remain Outside CBAM Post-2026

THIS BLOG IN SHORT

The current CBAM regulation states that from 2026 onward, indirect emissions from aluminum, hydrogen, and iron/steel will not be covered. This decision aligns with the existing policy framework, as these sectors receive financial compensation from the EU to offset the high electricity prices resulting from the emissions trading system (one estimate being that for every €1/ton increase in EUA prices, wholesale electricity prices can rise by approximately €0.5–1.2/MWh, depending on how carbon-intensive the marginal producer). Consequently, there are two possible policy directions for the future:

Maintain the Current System: Continue compensating industries for high electricity prices while excluding indirect emissions from CBAM. This approach would avoid regulatory changes and ensure stability for industries concerned about logistical challenges.

Expand CBAM Scope to Include Indirect Emissions: Eliminate compensation payments and include indirect emissions under CBAM, allowing EU industries to be protected through CBAM revenues while reducing public spending on subsidies.

The Marginal Pricing Mechanism for Electricity in Europe 

In the European electricity market, prices are set through a marginal pricing mechanism. Power generators submit bids indicating the price at which they can produce electricity, ranked from the lowest to the highest cost. The price for a given period is then set by the last (i.e., most expensive) unit of electricity required to meet demand—a concept often known as the merit order (European Commission, 2020a).

Because many renewable energy sources, such as wind and solar, have near-zero marginal costs, they are dispatched first. However, during periods of high demand or low renewable output, the market turns to fossil fuel generators with higher operating costs. These generators set the marginal price that all market participants pay, regardless of which source produced their electricity.

High Electricity Prices and Their Impact on Energy-Intensive Sectors

The reliance on fossil fuel plants to set market prices means that electricity costs in the EU tend to be high during peak demand periods. Indeed, even if fossil fuel plants are more expensive to operate and have significant carbon costs under the EU ETS, they are required when renewable energy supply is insufficient (European Commission, 2020b).

Compensation for Energy-Intensive Sectors

Industries highly sensitive to electricity prices, such as aluminum, iron/steel, and hydrogen, are particularly affected by these high costs. To ensure these industries remain competitive and prevent carbon leakage, the EU has implemented compensation mechanisms. These funds help to mitigate the financial burden imposed by high electricity costs resulting from the marginal pricing system (European Commission, 2021).

Policy Scenarios: Keeping Compensation vs. Expanding CBAM Scope

Currently, CBAM excludes indirect emissions from aluminum, hydrogen, and iron/steel after 2026. However, two policy paths are possible:

Scenario 1: Maintain Compensation & Keep Indirect Emissions Outside CBAM

  • Avoids Disrupting Industry Practices: Industries may prefer stability and logistical clarity instead of restructuring compliance systems.
  • Ensures Ongoing Support: Compensation funds would continue to offset high electricity costs.

Scenario 2: Expand CBAM to Include Indirect Emissions & Remove Compensation

  • Reduces Public Spending: Eliminating compensation programs would allow the EU to save funds while shifting industry support to CBAM revenue.
  • Preserve the Carbon Leakage Protection: Covering indirect emissions in CBAM would ensure a level playing field by preventing imports from benefitting from lower electricity costs.

Regulatory Outlook: A Decision That Will Shape Industry Competitiveness

While CBAM is currently set to exclude indirect emissions after 2026, policymakers must weigh the trade-offs between continuing compensation programs or expanding CBAM coverage. If indirect emissions remain outside CBAM, the EU will need to keep sustaining its compensation programs. However, if CBAM is expanded, industries would shift from receiving direct financial support to relying more on CBAM revenues as protection against carbon leakage.

 

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