Carbon Border Adjustment Mechanism gaining traction in Europe

Edge2020_Carbon Border Adjustment Mechanism

The European Parliament is introducing new climate legislation including a Carbon Border Adjustment Mechanism, in a bid to reduce greenhouse gas emissions.

The new package aims to reduce emission by at least 55% by 2030 and will include a series of measures which will have big impacts to many large industry customers who now will have millions of tonnes of carbon at risk.

The proposal will include phasing out of the free European Emission Trading Scheme (ETS) allowances after 2026, including maritime shipping within the ETS and a Carbon Border Adjustment Mechanism. The latter of these the CBAM or Carbon Border Adjustment Mechanism will impose a tariff on goods whose production is carbon intensive and shows the greatest risk of carbon leakage, in Australia the most vocal opponents of this scheme are unsurprisingly the cement, aluminium and steel industries.

As a quick digress the term carbon leakage is referring to the idea that you move the most carbon intensive parts of your production abroad, into countries with less stringent climate policies, and then import them back into Australia.

The idea of the CBAM is this will place a price on the carbon which has been emitted during this production phase. The price being derived from the price of carbon which was paid for the product to be developed and produced within Australia.

Those keen eyed amongst us will remember the Safeguard Legislation, which will come into effect on the 1st July 2023, cited a review would be undertaken to examine the feasibility of a CBAM within Australia, including a consideration for early commencement for those high-exposure sectors such as steel and cement.

Now with the EU making the leap and the likely follow on from the UK, Japan and Canada, amongst others, including the US via its own Polluter Import Fees Australia, we will surely have to comply to ensure both our own goods are being protected as well as meeting the requirements of the global expectations.

However, what is the cost of compliance. Whilst the legislation is quite straight forward the compliance cost will increase. Cradle to gate / grave accounting is complex and with auditors being stretched between, NGERs, Safeguard and now this, finding a resource to complete the calculations and data collection will be one thing, but looking to have these accounts audited will be another. With the CER having only 75 registered auditors on their books will the cost of this be wider than the government are imagining?

Chubb report

Chubb report carbon offset

The long-awaited Chubb report was published on Monday 9th January 2023. Its purpose to “ensure Australian Carbon Credit Units (ACCUs) and the carbon crediting framework maintain a strong and credible reputation supported by participants, purchasers and the broader community.1

The government has agreed (in principle) to enact all the proposed recommendations.

But let’s start at the beginning. The Chubb review came about following claims that the scheme was not robust, being managed badly and not fit for standards, especially on the international stage.

Following the King report in 2020 this view was exacerbated by the Clean Energy Regulator (CER) taking on an even larger role in this opaque market, holding the keys to the design of ACCU methodologies, registration and regulation of those projects, a data source for the “independent” ERAC (the Emissions Reduction Assurance Committee – the independent committee overseeing the ACCU market) and buying ACCUs on behalf of the Australian Government. Some may say it was a keys to the castle type deal.

Therefore, transparency and independence were unsurprisingly the key focus for the Chubb review. Both from the regulatory and data access standpoints, obviously maintaining privacy where required. With upcoming changes in the Safeguard Mechanism expected to come into force in the new financial year and increasing interest in ACCUs from the Hydrogen industry (to ensure certification meets international standards such as CertifHy) the robustness of the scheme must be unimpeachable.

I think the most interesting part of the review is the u-turn from the previous Morrison government’s stance, which mandated in 2021 that their own Climate Active standard would have required members to increase their “carbon neutrality” through a minimum of 20% or 30% ACCUs dependant on size. This reversal, to no such mandate, is showing the business community at least that an international certification is enough for this government. Not the strong climate stance that is being pitched from the floors of Canberra.

As with many of these papers I am finding little accountability and more future safeguarding. Especially around human-induced regen (noting that ends this year), carbon capture and storage and landfill waste gas, with no individual projects reviewed, the current standard of certification cannot be confirmed, yet it is likely to be significantly tightened if the advised transparency is enforced.

Overall, I can’t help feeling this was not more than a necessary boondoggle, yes some interest groups have had some wins, but it was necessary to achieve its end – it is going to undo a significant number of the controversial King review and Morrison Government changes.

Reversal however will come at a price, there will likely be a significant amount of funding put in place to reduce the both “real and perceived,” burden on both the CER and especially the Emissions Reduction Assurance Committee (ERAC). The latter of whom will be dis-banded and renamed the Carbon Abatement Integrity Committee (CAIC), moved out from the CER with full data access restored and with a remit which, if enacted within 6 months, could see them as an Independent Statutory Authority, a level the ERAC currently hold but are handcuffed from enacting upon.

Personally, I think any changes which bring transparency to this market, its accreditations and oversight can only be positive. There is still the government tender for an ACCU exchange to be developed which would further assist this transparency, but I also fear it has stopped short of really making the Carbon Market in Australia un-penetrable.

With Climate Active still supporting accreditations from Certified Emissions Reductions (CERs), Verified Carbon Units (VCUs) amongst others and an increasing number of lesser regulated Carbon Neutral certificated (iRECs etc) being used for Carbon Neutral Claims, I think this review could have used its opportunity to ensure the Australian Carbon Neutrality Certification would be seen as a world leader. Instead, I fear it is trying not to shake an already leaking boat, with pressure for ACCUs likely to increase with Safeguard changes and the HIR methodology ending in 2023, as well as the new “REGO” scheme being touted as “voluntary surrender only” with no regard for the impact to the LGCs market. Another knee jerk could have put too much price pressure on a market which is not only opaque but likely to come under significant demand, and that is before the increased scrutiny once data is widely available.

No, the Chubb review has done its job, it has unwound a lot of the misgivings people had. It should increase transparency, a feat which has been loudly called for in this market since its inception 11 years ago and not ruffled too many feathers in the process. I guess I just hoped for more.

References: 1:

Kate Turner is Edge2020’s senior manager markets, analytics and sustainability. Through a passion that renewable energy solutions are key to any climate change solution, Kate supports our clients to manage their portfolios and any associated risk within traditional markets as well as complex renewable energy portfolios. Kate is hands on in procurement development and implementation for our clients and leads our market regulatory and advisory sustainability services. If your business is interested in wholesale or retail renewable PPAs we’d love to help you. Contact us on: 1800 334 336 or email:

Does another new environmental scheme create more uncertainty?

Australia's renewable energy schemes

In December the Department of Climate Change, Energy, the Environment and Water released two papers. One on Renewable Electricity certification and one on the Guarantee of Origin Scheme.

These are mainly aimed at the hydrogen industry but the first could have a significant impact on the electricity sector if the proposals are implemented as per the position paper.

The Renewable Electricity Certification paper asks for feedback on the need for a new mechanism for electricity to be certified, currently to be used only for voluntary surrender purposes. It proposes it will act alongside LGC creation (Large-scale generation certificates) with the developer able to decide if they produce an LGC or a REGO (Renewable Energy Guarantee of Origin certificate) on any given period, in any given day.

The REGO can be used for all uses, bar RET liability i.e., voluntary surrender.

The main difference of the REGO to the LGC elements being proposed in the paper are:

  • It proposes to allow the use of below-baseline generation to create a REGO.
  • It will also allow STCs systems to create a REGO once the maximum deeming periods from date of installation has been met. If the minimum threshold isn’t met they can aggregate multiple small scale systems to create a certificate.
  • Further it suggests almost a double counting whereby a battery could purchase REGOs to “store” green electricity then re-sell as green electricity with a new REGO.
  • For exporting renewable energy i.e. Sun Cable whereby the REGO can be created even though the electricity is exported overseas, this is not allowed under the RET scheme for LGCs. How we can claim that against a domestic usage is yet to be seen!
  • There is a proposal any vintage can be surrendered at any time for this year’s claim
  • It is also worth noting a REGO would require a time stamp under the proposals – meaning hourly matching could be undertaken. However, a note for is you are in an aggregated system for the REGO the last hour to make the 1MWh REGO would be the one counted.

It is proposed this will allow claims post the sunsetting of the RET in 2030 but does not go as far as to state it will replace the RET – however this must be implied that it is the intention of the scheme.

If this is to go ahead there are a few concerns:

  • Will it crash the price of the LGCs?
    • Could the market be flooded with “equal value” REGO certificates and bar RET liability the LGC market move?
  • Alternatively – What happens to the LGC market if everyone signs up to REGOs – would it mean LGCs could potentially go up in price as people are only creating REGOs and the LGC RET liability can’t be met
  • Will it increase volatility with an arbitrage being available between the two schemes?
  • Does this really level the playing field for Hydrogen in the way they think it will? I am not sure we meet all criteria in the market leading hydrogen certification markets with this proposal
Consultations close 3rd Feb but this is one to watch. It may be being pushed through a side door but it could blow open the LGC market as we near the end of the RET scheme. Have your say here: