@sandbag-eu.bsky.social
We conduct data-driven and evidence-based advocacy to improve EU climate policy.
The mutual benefits of systematic default values
✅ Close loopholes and prevents resource shuffling
✅ Cut admin burden and protect sensitive data
✅ Support systemic decarbonisation in exporting countries
📄 Read Sandbag's full brief:
sandbag.be/2025/08/06/s...
Electricity imports — capturing real impacts
Electricity import emissions come from grid impact, not just electricity source.
⚠️ Current rules miss this.
✅ Solution 1: Use “induced emissions” – reflect marginal fossil generation
✅ Solution 2: Apply systematic default values
Indirect emissions — closing the PPA loophole
⚠️ CBAM counts renewables as zero-emissions via PPA/direct link, but this can still trigger fossil use.
✅ Solution 1: Use "induced emissions" – reflect fossil use at the margin in exporter grids.
✅ Solution 2: Apply default electricity factors
Cement — the clinker substitute loophole
Exporters can send low-clinker cement to the EU, but keep high-clinker cement at home.
⚠️Emissions stay the same
⚠️ This resource shuffling undermines the CBAM’s goal
✅ Solution: Report cement emissions using default values systematically
Steel & aluminium — closing the scrap loophole
CBAM assumes steel/aluminium scrap has no emissions.
⚠️ This lets exporters blend in scrap to cut CBAM costs — with no real climate benefit.
✅ Solution: Attribute emissions to scrap + report steel emissions using default values systematically
Strengthening the CBAM by default
The EU is reviewing the CBAM to:
• Cover downstream products
• Tackle circumvention
• Improve electricity emissions rules
Sandbag's supports proposals to improve, simplify and close loopholes and reduce costs in the CBAM.
👇 See how the CBAM can be improved
📘 Want the full details?
Read Sandbag’s latest brief on why CBAM must cover indirect emissions — and how to reform ICC to make it work.
👉 sandbag.be/2025/08/01/w...
How indirect emissions reporting should be reformed
📌 Induced emissions should be counted as part of indirect emissions embedded in imported goods
📊 Alternatively, default values should be used systematically
📎 Default values should be based on country average or marginal emission intensity
With the CBAM, resource shuffling and shifted emissions become a concern
🔋 Indirect emissions embedded in imported goods are considered as zero if the electricity used is renewable
🧳 This incentivises CBAM circumvention via resource shuffling
🔥 Marginal fossil power use drives induced emissions
ICC subsidies should only be paid when fossil generation drives electricity prices
🚫 This will ensure electricity users are not over-compensated
📈 This will ensure ICC subsidies are gradually phased out as EU electricity prices get less driven by fossil generation
Indirect carbon cost (ICC) compensation should be linked to low-carbon power use
🕰️ Currently, Member States compensate their industry’s ICC based on the amount of power use, whichever, whenever
🌱 Instead, ICC subsidies should be limited to the low-carbon share of electricity used
The CBAM should cover indirect emissions
⚡️ To improve environmental integrity
🏭 To avoid competitive disadvantages for EU plants
💶 To reduce fiscal burden, as EU governments currently compensate for indirect carbon costs through costly subsidies
🔌 To prepare the CBAM to an electrified future
📣 Why the CBAM must include indirect emissions
The EU is considering whether the CBAM should cover emissions from electricity used in the production of imported goods.
Sandbag’s new briefing shows why this is necessary — and how to make it work. 👇
📄 Full briefing here: sandbag.be/2025/07/08/t...
Smart reform can make the Fund a more powerful tool for climate action.
🌫 Fourth: Account for induced emissions
When there is already demand for fossil electricity, extra electricity use, even renewable, will induce more fossil generation. Those induced emissions should be counted.
⚡Third: Fix unrealistic electricity assumptions
Current rules assume electricity used by projects will have zero emissions.
This is unrealistic and masks the real carbon footprint of many projects, especially those needing power 24/7.
🧭 Second: Prioritise funding where it’s needed
Scale-up Funds should be performance-based, but prioritise:
•Sectors of activity without big private backers
•Production facilities not receiving free EU ETS allowances
💡 First: Support real technology risk
Too much money is paid before projects operate.
This shifts risk to taxpayers and weakens performance incentives.
Only truly projects with technology risk should get upfront grants.
The EU Innovation Fund is missing its potential.
Sandbag responded to the EU consultation with 4 key changes to ensure smarter funding. 👇
Only one method reflects real emissions: the one based on which power plants are actually running when hydrogen is made.
❌ Averages miss fossil ramp-up.
📉 Sandbag’s analysis:
sandbag.be/2025/06/12/g...
#Hydrogen #CarbonAccounting #NetZero
🌍 Not all “green” electricity is low-carbon.
EU hydrogen rules let producers use grid averages — but these miss real-time fossil impacts.
⚠️ Emissions depend on when power is used.
👇
The #IDAA is a chance to set the record straight on what counts as “green steel.”
Labels must:
✔️ exclude fossil-based production routes
✔️ use dynamic benchmarks
✔️ reflect full life-cycle emissions
🔗 sandbag.be/2025/07/14/p...
#ClimatePolicy #Steel #CarbonMarkets
📢 New report out now:
Simulating CDR in the EU ETS: The Risks of Premature Integration
👉 sandbag.be/2025/07/09/s...
We explain why CDR shouldn't enter the ETS before 2040.
🇪🇺 The EU ETS is set to be revised – and it’s a critical opportunity to fix what’s broken.
📝 Sandbag’s response to the EU consultation:
– End free allocation
– Restrict aviation EUA access
– Link ICC to clean power
– Reform Innovation Fund
🔗 sandbag.be/2025/07/08/t...
📢 The EU’s 2040 climate target relies on international credits & CDR in the ETS.
These “flexibilities” could delay crucial domestic emission reductions.
🗓️ 9 July: Sandbag's webinar explores CDR’s potential impact on ETS.
👉 Register for the webinar: lnkd.in/ezYGjDMS
#EUClimate #CarbonMarkets
📢 Upcoming Webinar: Simulating CDR integration in the EU ETS – Exploring the Trade-offs
SandbagClimate’s new simulator shows the risks: displaced emissions cuts & unbalanced CDR.
🛠️ Join our webinar:
🗓️ 9 July, 11:00-11:40 CEST
🔗 lnkd.in/ezYGjDMS
#EUETS #CDR #CarbonMarkets #ClimatePolicy
How can we finance permanent removals without slowing deep decarbonisation?
At #CO2olDown Phase 2, Sandbag’s Duncan Woods joined a co-creation workshop to explore short-term strategies.
📝 Recap: carbonmarketwatch.org/2025/05/27/c...
Thanks @carbonmarketwatch.bsky.social @dreamocracy.bsky.social
New from Sandbag. Using more RFNBOs to meet RED III may raise—not cut—emissions if grid timing isn’t aligned. ⏱️⚡
❗Direct electrification is the most efficient path. We must prioritise how electricity is used.
🔗Read Here sandbag.be/2025/06/12/g...
#ClimatePolicy #Electrification #RFNBO
🌍 We’ve signed a joint letter urging the EU:
Don’t outsource the 2040 climate target
🚫 Article 6 offsets = weaker ambition, higher costs & lost credibility
📉 Undermines the EU Climate Law
✅ Experts call for at least 90–95% domestic cuts by 2040.
🔗 sandbag.be/2025/06/12/e...
#EU2040
📢 Sandbag joins 30+ civil society orgs urging standards bodies to reject a “mass balance” approach promoted by Japan’s steel industry.
It would allow emissions cuts from one site to be reassigned — letting coal-based steel appear green.
🔗 tinyurl.com/47kcz43s
#Steel #Greenwashing
