Carbon border adjustment mechanism consultation response
Position Paper
27 Oct 2020
Customs and trade facilitation , Tax, Trade, Energy

AmCham EU submitted a response to the open public consultation for the upcoming proposal for a carbon border adjustment mechanism (CBAM) in the EU. As part of the European Green Deal and Europe's recovery plan, one of the main objectives of the measure is to mitigate carbon leakage and help the EU reach its objective of climate neutrality by 2050. AmCham EU and its member companies have the required expertise to contribute to the policy debate and we welcome opportunities to engage in the discussion on the best possible policies to encourage low emission production and to support a fair and level playing field. Our response details our perspectives on the following: objectives of CBAM; the design of the mechanism; Scope; WTO compatibility; potential exemptions and the calculation of carbon content of products.

Please download the file to view AmCham EU's response to the public consultation as well as an accompanying position paper. 

For more information, please contact Nadia Allen, Senior Policy Adviser (NAL@amchameu.eu

Related items

Position Paper
25 Nov 2025

Defining ‘Made in Europe’: embracing smart investment incentives and allied cooperation

European policymakers are increasingly focused on strengthening the EU’s strategic autonomy, reducing strategic dependencies and building greater resilience across critical sectors. This drive is rooted in legitimate concerns about ensuring access to essential goods, increasing the diversity of supply chains and enhancing the EU’s ability to respond to geopolitical and economic challenges. As the EU seeks to address these challenges, its core objective should be to leverage its extensive partnerships and use smart incentives to support the bloc’s long-term competitiveness and security.

Lawmakers are actively considering ways that ‘Made in Europe’ criteria could support these objectives in virtually any process requiring clearance, approval or an auction. Global examples of domestic preference and non-price criteria demonstrate two things. First, if they are designed poorly, they could reduce competitiveness, simplification and resilience. However, they also demonstrate that if they are designed well, they can maximise the value of allies’ economic participation and improve the functioning of the processes they are applied to.

The US’s various ‘Buy America’ programmes provide a useful case study for assessing the risks of different ‘Made in Europe’ regimes. While US procurement and funding programmes with ‘Buy America’ provisions are generally open to foreign-headquartered participants (and actively encourage their participation), they also bring certain categories of risk that should be considered before bringing them to the EU.

If ‘Made in Europe’ effectively excludes firms headquartered in the US and other allied nations, including EU-based subsidiaries of US-headquartered firms, the EU risks introducing more complexity into European public procurement markets and funding programmes. This would ultimately diminish competition and the quality of products and services, while increasing costs and elevating trade tensions that may decreasing the market access of EU-headquartered companies abroad. At a time when the EU is facing urgent competitiveness challenges, policymakers should avoid pursing reactive security and resilience policies that would undermine the EU’s competitiveness goals.

However, if thoughtfully implemented, certain ‘Made in Europe’ regimes could leverage the EU’s Single Market and international partnerships to improve the EU’s competitiveness and resilience.

Competition
Transatlantic
Industry
Trade
Read more
Read more about Defining ‘Made in Europe’: embracing smart investment incentives and allied cooperation
Position Paper
6 Nov 2025

Implementing the EU-US Framework Agreement: Priorities for adopting the Commission’s tariff reduction proposals

Implementation of the EU–US Framework Agreement is essential to bring greater stability to transatlantic trade and investment. With the Commission’s tariff reduction proposals now before the European Parliament and the Council of the EU, swift adoption is critical to help businesses plan ahead. The co-legislators should therefore: 1) stick to the agreed scope, 2) avoid unnecessary duplication and 3) focus on restoring predictability for businesses. Following these principles will ensure the EU and the US can continue building on the Agreement while preventing a tit-for-tat that would harm both sides.

Trade
Trade tensions
Read more
Read more about Implementing the EU-US Framework Agreement: Priorities for adopting the Commission’s tariff reduction proposals
Position Paper
4 Nov 2025

A Circular Economy Act for a sustainable and competitive Single Market

The upcoming Circular Economy Act represents a crucial opportunity to address longstanding business challenges through simplification and the strengthening of the Single Market. Its success depends on revising the Waste Framework Directive (WFD) and the Waste Electrical and Electronic Equipment (WEEE) Directive, re-opening some provisions of the Waste Shipment Regulation (WSR) and the Single Market Transparency Directive, promptly adopting secondary legislation under the Packaging and Packaging Waste Regulation (PPWR) and implementing financial flanking measures where necessary.

Environment
Energy
Read more
Read more about A Circular Economy Act for a sustainable and competitive Single Market