Executive Summary

The implementation of a watertight CBAM is indispensable to reach the cement industry’s climate ambition. This position paper highlights the key risks of CBAM fraud and circumvention in the cement sector, following a thorough analysis conducted by CEMBUREAU and its members. Based on this analysis, several key steps are necessary to ensure CBAM’s watertightness:

• The European Commission should continue to develop the necessary secondary legislation on CBAM, taking as guiding principle the need to mirror the EU ETS as strictly as possible. The Delegated/Implementing acts on CO2 measurement (including on indirect emissions), accredited verifiers, and the taking into account third countries pricing scheme, will be particularly crucial.
• In view of the start of CBAM’s operational phase in 2026, default values and their markup should be set a high level to avoid free-riding behaviour and protect the environmental integrity of CBAM.
• The biggest risk of CBAM fraud in the cement sector relates to false declarations on cement blends. Clear mitigation measures should be taken against this risk, which represents very significant financial amounts but is, for the time being, constrained to a limited type of imports. Refining the EU customs code and adopting a risk-based approach through sampling are two solutions that will largely mitigate the risk of fraud, at a minimal cost.
• More broadly, both the European Commission, CBAM competent authorities and national customs authorities should be appropriately resourced to undertake their tasks under CBAM. The roles and responsibilities of each institution in checking the veracity of CBAM reports and fraudulent behaviours should also be clarified through a clear plan.

Read the full article here