CBAM Carbon Price Adjustment Rules: Feedback by VDZ (German Cement Works Association)

VDZ welcomes the opportunity to provide brief feedback on the European Commission’s proposal of an Implementing Regulation regarding the conversion of third-country carbon prices into a corresponding reduction of CBAM certificates to be surrendered (Ares(2026)4841230 as of 13 May 2026). In the view of VDZ, the proposal contains several important elements that can contribute to a fair and workable application. However, several provisions risk creating distortions between EU and non-EU producers and may unintentionally open new avenues for circumvention. Preserving a genuine level playing field with the EU ETS must therefore remain the guiding principle throughout the Regulation. Further details can be found in the following PDF file.