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The European Commission has launched a public consultation on CBAM, and ZETA is responding with its first formal position paper.
The consultation invites feedback on potential downstream scope extensions, anti-circumvention measures, and rules for electricity, as well as their social, economic, environmental, and administrative impacts.
In our submission, ZETA raises concerns about how CBAM currently applies to electricity imports into the EU. The framework makes it too onerous for renewable electricity producers in neighboring non-EU countries to demonstrate their actual low-carbon intensity, forcing them to use grid emission averages. This approach risks discouraging renewable investment outside the EU slowing the broader energy transition by undermining cross-border trade, and ultimately increasing carbon intensity in interconnected systems.
