AEGIS Europe’s Letter to President von der Leyen on CBAM
14 September 2026
Dear President von der Leyen,
Dear Executive Vice-President Séjourné,
Dear Executive Vice-President Ribera,
Dear Commissioner Hoekstra,
Dear Commissioner Šefčovič,
AEGIS Europe is an industry alliance that represents more than 30 European manufacturing associations and companies across entire industrial value chains, from metals and ceramics to transportation industries.
The ongoing review of the Carbon Border Adjustment Mechanism (CBAM) provides a crucial opportunity to ensure that the instrument effectively safeguards the competitiveness of European industry while delivering on its climate objectives. While we welcome the European Commission's efforts to address export-related carbon leakage and strengthen anti-circumvention measures, the current proposals remain insufficient to provide the long-term certainty and protection that EU industries require.
We therefore urge the Commission to complement the proposed Temporary Decarbonisation Fund (TDF) with a durable structural solution for exports and to reinforce the CBAM framework with more robust and effective anti-circumvention provisions.
The TDF should primarily compensate EU exporters of CBAM‑covered goods in order to mitigate the risk of product reshuffling. In a second step, it should support EU downstream exporters using CBAM‑covered inputs that face a significant cost increase due to higher carbon prices of imported precursors. Compensation will have to be brought forward to 2027 and earmarking a clearly defined financial allocation for the most exposed sectors. However, the TDF cannot substitute a long-term structural solution for EU export sectors impacted by CBAM. The European Commission should therefore earmark dedicated financial support within the forthcoming EU Multiannual Financial Framework, providing long‑term certainty for EU producers. As free allocation declines and CBAM costs materialise, export-oriented sectors face increasing competitiveness pressures in third-country markets. A long-term solution needs to be proposed urgently and compensate EU exporters for the increased ETS costs. The raw material cost increase CBAM will generate for importers of CBAM covered goods should also be acknowledged and compensated. Export adjustments must be part of the CBAM design to ensure that European exports do not become uncompetitive on foreign markets. This long-term solution should reflect the free allocation phase out trajectory, maintain decarbonization incentives, and be explicitly linked to export exposure. It should be included in the ETS review proposal which is expected mid-2026. AEGIS Europe proposed a WTO-compatible solution.
Additional anti-circumvention measures: European Commission’s proposals to address circumvention are welcome as a first step but need to be further strengthened to secure CBAM delivers on expectations. A clearer political mandate from co-legislators is necessary, with more visibility on the countermeasures, notably via the application of default values. The European Commission’s definition of “abusive practices” seems too narrow, and the risk of resource shuffling needs to be effectively addressed. The effectiveness of its proposals needs clarification in the CBAM regulation, before it is implemented in secondary legislation. Both the European Commission and competent authorities must have sufficient resources and capacities to identify and address circumvention through effective controls and concrete measures. As CBAM has just entered its definitive period, potential abusive practices remain open-ended and should be regularly assessed by the Commission, while CBAM-related cost absorption should also be considered. We welcome the inclusion of OLAF in the CBAM Registry High Level architecture but believe its role should be strengthened through an enhanced investigative mandate, improved access to real-time data, and the power to launch investigations into suspected circumvention on its own initiative, particularly in cross-border fraud cases.
We remain at your disposal should you require any further information or wish to discuss these issues in greater detail.
Sincerely,
Inès Van Lierde, Renaud Batier
Co-Chairs
AEGIS Europe
AEGIS Europe’s key messages on CBAM
· AEGIS Europe supports a CBAM that is efficient in addressing carbon leakage risks while ensuring a level playing field on both European and foreign markets
· Simplification attempts are welcome, but not at the expense of effectiveness in preventing carbon leakage. Simplification should not facilitate or lead to circumvention
· CBAM needs a WTO-compatible export solution for producers of CBAM goods to avoid carbon leakage and the replacement of EU low-carbon products with high-carbon alternatives on global markets
· Anti-circumvention rules must be strengthened to ensure the effectiveness of the measure and avoid practices such as resource shuffling or cost absorption
· CBAM alone cannot solve the carbon leakage issue for all sectors, especially ETS sectors it covers with very specific value chains, products, and global trade flows. For these sectors, a stronger carbon leakage protection and additional measures are needed