Bioenergy Europe’s contribution to the CBAM Draft Act consultation
Making CBAM work for Europe’s clean technology manufacturers
Bioenergy Europe’s feedback on the CBAM Draft Act consultation looks at how the EU can prevent carbon leakage without creating extra pressure on European clean technology manufacturers. The document supports CBAM’s climate objective, but warns that higher costs for materials such as steel and aluminium could affect producers of renewable heating and bioenergy technologies, including biomass boilers, pellet stoves, CHP systems and district heating equipment.
The feedback calls on the European Commission to assess these impacts carefully before changing the CBAM framework. It also stresses that any extension to downstream products should be based on clear criteria and matched with a workable solution for export competitiveness, so EU manufacturers are not disadvantaged in global markets.
Bioenergy Europe supports the EU’s climate objectives and the role of the Carbon Border Adjustment Mechanism in preventing carbon leakage. A fair carbon framework is important to protect European industry and support the transition towards cleaner production. At the same time, CBAM must be designed carefully to avoid unintended effects on the companies manufacturing the clean technologies Europe needs for its own decarbonisation.
This is particularly relevant for renewable heating and bioenergy technologies, such as biomass boilers, pellet stoves, combined heat and power systems and district heating equipment. These products rely on materials such as steel and aluminium, which are covered by CBAM, and are produced in a highly competitive global market.
If carbon-related costs increase the price of inputs for European manufacturers, while competing finished products imported from outside the EU do not face the same costs, EU-made clean technologies could become less competitive. This would risk weakening European manufacturing capacity in sectors that directly support the EU’s climate and energy goals.
Higher equipment costs could also slow down investment in renewable heating, CHP and district heating projects. This would affect not only manufacturers, but also operators looking to invest in new clean energy capacity in Europe.
Bioenergy Europe therefore calls on the European Commission to carefully assess the impact of CBAM on downstream clean technology manufacturing when considering future changes to the framework.
Any possible extension of CBAM to downstream products should be based on clear and objective criteria, including carbon intensity, trade exposure, carbon leakage risk and the share of CBAM-covered materials in the final product.
Before extending CBAM to downstream clean technology products, the EU should also establish a workable solution for export competitiveness. European manufacturers should not face carbon-related costs in their production inputs without an appropriate adjustment when they sell their products outside the EU.
Where downstream clean technology manufacturers are clearly affected, the Commission should consider temporary and targeted support measures, such as a compensation mechanism. Such measures should remain proportionate and focused on sectors exposed to international competition.
Aligning carbon leakage prevention, industrial competitiveness and clean technology manufacturing is essential. CBAM should help Europe decarbonise industry while keeping the technologies needed for that transition made in Europe.
