Displaying items by tag: carbon border adjustment mechanism

The Hungarian government recently enacted Emergency Decree 320/2023, taxing all CO₂ emissions from the country’s 40 or so largest industrial enterprises. The government used emergency powers to set up a new taxation scheme, which undercuts existing free allowances under the EU emissions trading scheme (ETS). The scheme additionally penalises the trade in ETS credits. Cement producers announced that the new regulations will make it impossible for them to keep operating.¹

With regard to Hungary’s six active cement plants, the scheme comprises:

1 – A Euro20/t tax on CO₂ emissions, effective retroactively from 1 January 2023, payable by any large enterprise that uses EU Emissions Trading Scheme (ETS) free allowances to cover the majority of its CO₂ emissions. Plants that decrease their production, or that carry on non-CO₂-emitting activities at over 10% of their operations, will pay a higher rate of Euro40/t of CO₂.

2 – A 10% transaction fee for the sale of free allocations under the EU ETS, payable to the Hungarian Climate Protection Authority.

Less than three years ahead of full implementation of the EU carbon border adjustment mechanism (CBAM), the Hungarian government has seemingly moved unilaterally against cement production – this in a country surrounded by seven other cement-producing countries. Multiple foreign cement producers connected to the major market of Budapest by rail, river and road will be watching developments with interest. These include CRH, which, besides two smaller plants inside Hungary, operates the 800,000t/yr Cementáreň Turňa nad Bodvou plant, immediately over the border in Slovakia.

This comes at a time when the domestic cement industry is facing historically high costs and low demand, with a 30% year-on-year decline in construction activity in July 2023, following double-digit inflation throughout 2022 and the first half of 2023.

Catastrophising may be a common symptom of environmental regulation in industry associations, but one can understand on this occasion. The Hungarian cement and lime industry association, CeMBeton, backed its members’ gloomy announcement about their future with an estimate for extra annual taxes of ‘several billion forints’ (1bn forint = US$2.84m), in a statement following the decree. Assuming annual CO₂ emissions of 565kg/t across its 5.4Mt/yr cement capacity, the sector might expect to pay US$61m/yr in CO₂ rates alone.^{2, 3} According to analyst ClearBlue, the government will raise additional tax revenues worth US$278m/yr across all of the 40 aforementioned heavy emitters in Hungary.⁴

It may seem surprising that CeMBeton did not even draw up a projected tax bill during consultations over the new tax scheme – but, in fact, no such consultations took place. In its most recent statement, the association said “We do not know the government’s intentions.” Outside of official releases, Hungary’s cement producers have not always been so reserved about the government’s perceived aim.

Global Cement reported in April 2023 that the Hungarian government was allegedly interfering in the cement sector to make producers sell up – as per accusations by an anonymous industry executive.⁵ There is arguably a course of action on the government’s part which, more or less, appears consistent with this aim:

October 2020 – The Hungarian Competition Authority (GVH) starts competition supervision proceedings against CRH, Duna-Dráva Cement and Lafarge Cement Magyarország.

July 2021 – Emergency Decree 2021/404 imposes a 90% tax on producers’ ‘excess’ profits, based on threshold cement sales revenues of Euro56/t. Additionally, producers must report their exports.

September 2021 – GVH finds insufficient evidence to support the initiation of competition supervisory proceedings in the cement industry.

January 2023 – (Retroactive) entry into force of CO₂ emissions tax.

May 2023 – The government of Hungary reportedly initiates negotiations to acquire Duna Dráva Cement and Holcim Magyarország, according to the Hungarian builders’ association, National Professional Association of Construction Contractors (ÉVOSZ). Duna Dráva Cement owners Heidelberg Materials and Schwenk Zement state that they have entered into no such negotiations, while Holcim declines to comment.

July 2023 – The Act on Hungarian Architecture lets the government dictate producers' volumes and prices and require them to supply cement to National Building Materials Stores (a proposed state-owned construction materials retail monopoly).⁶ Additionally, the government gains a right of first refusal over the divestment of any asset by the cement industry’s foreign owners.

20 July 2023 – The government enacts Emergency Decree 320/2023. ETS transaction fees enter into force.

The government can now expect a legal challenge to its latest move. CeMBeton’s first ally may be the font of all emissions legislation – the EU itself. Within the EU ETS framework, tax rates are down to member states to determine. However, the introduction of a transaction fee may constitute an illegal restriction to free allowances, OPIS News has reported. The association has also indicated its readiness to mount a constitutional challenge, specifically with regard to the legislative retrofit involved in the CO₂ emissions tax. The Fundamental Law of Hungary does not generally permit legislation to apply retroactively, though how courts will balance this consideration against the rights of the government is untested.

The government amended the constitution to provide for new emergency powers, and subsequently adopted them in May 2022, in response to the ‘state of danger’ created by Russia’s war in Ukraine – though its actions on the international stage suggest careful neutrality, if not ambivalence. At home, the war has brought a consolidation of the government’s control over various areas of life, including the economy, according to Human Rights Watch.⁷

Climate protestors around the world might be glad to see governments wield emergency powers against their own heavy industries. In Hungary, however, the wider sustainability goals are not yet clear with regard to a policy that seems, at least partly, politically motivated.

References

1. CeMBeton, Sajtónyilatkozat, 21 August 2023, https://www.cembeton.hu/hirlevel/2023-08-21/202308-mozgalmas-osz-ele-nezunk/116/sajtonyilatkozat/668

2. Heidelberg Materials, ‘Energy and climate protection,’ 2022, https://www.heidelbergmaterials.com/en/energy-and-climate-protection

3. Global Cement, Global Cement Directory 2023, https://www.globalcement.com/directory

4. OPIS News, ‘Hungary's New Carbon Tax Unlikely to Set EU Precedent, Say Analysts,’ 16 August 2023

5. Global Cement, 'Update on Hungary,' April 2023, https://www.globalcement.com/news/item/15572-update-on-hungary-april-2023#:~:text=Heidelberg%20Materials'%20subsidiary%20Duna%2DDr%C3%A1va,the%20country's%20active%20national%20capacity.

6. Daily News Hungary, ‘Hungarian government’s new nationalising plan could violate EU law,’ 27 February 2023, https://dailynewshungary.com/hungarian-govts-new-nationalizing-plan-could-violate-eu-law/

7. Human Rights Watch, ‘Hungary’s New 'State of Danger',’ 8 June 2022, https://www.hrw.org/news/2022/06/08/hungarys-new-state-danger

New Zealand: Fletcher Building says that its subsidiary Golden Bay cement is waiting to embark on a US$119 – 178m course of capital expenditure (CAPEX) investment. However, the group said that it will first require ‘clarity from the government’ on any upcoming changes to industrial CO2 emissions allocations or border adjustments.

CEO Ross Taylor said “Until we get certainty there, we really can’t pull the cord.” He added “There’s a good pipeline of existing stuff which will really start maturing in two or three years, but there’s another really sizeable pipeline beyond that.”

Fletcher Building invested a total of US$182m across its businesses during the 2023 financial year, which ended in June 2023. The Bay of Plenty Times newspaper has reported that the investments are part of the group’s growth strategy for the four-year period up to the end of the 2027 financial year. Planned areas for investments include adding value to the group’s wood products by developing its alternative fuel (AF) capacity. The growth strategy has a budget of US$474m.

Europe: The EU has enacted the implementing regulation for the carbon border adjustment mechanism (CBAM) under its emissions trading scheme (ETS). Under the CBAM, importers of cement to the EU will eventually pay taxes for its embedded CO₂ emissions, equivalent to those levied against EU-based producers. Importers must begin to collect emissions data from 1 October 2023, and submit a report for the fourth quarter of 2023 to EU authorities by 31 January 2024. No financial adjustment will yet be payable during the transition period to full CBAM implementation from the start of 2026.

The Asset newspaper has reported that dedicated IT tools and training materials for importers affected by the CBAM are currently in development, according to the European Commission.

Australia’s Climate Change Minister announced plans this week to look at a potential carbon border adjustment mechanism (CBAM). Chris Bowen told an Australian Business Economists forum in Sydney that policies were needed to ensure a level playing field for Australian firms. Mentioning the European Union’s (EU) CBAM by name, he said that his department would prepare a review to assess carbon leakage risks, develop policy options and look at the feasibility of an Australian CBAM, particularly in relation to steel and cement.

The Antipodean nation has past form when it comes to carbon legislation. Back in 2012 it introduced the Clean Energy Act under the Gillard administration. The legislation was intended to introduce an emissions trading scheme with a carbon pricing scheme. However, it faced opposition from rival political parties and the Cement Industry Federation warned that the local cement sector was vulnerable to overseas competitors outside of the scheme. Job losses followed and Adelaide Brighton appeared to react by focusing more on imports. The Abbott administration then abolished the act in 2014 putting forward its Clean Energy Future package instead, which focused more on investing towards change. Jump forward nearly a decade and the Albanese government passed its Climate Change Bill in 2022. This set legally binding targets, including a commitment to cut CO2 emissions by 43% from 2005 levels by 2030. Bowen’s look at a CBAM is an obvious next step from here, addressing one of the main criticisms of the previous Clean Energy Act.

Local building materials company Boral reacted positively to a CBAM in its annual results released earlier this week with chief executive officer Vik Bansal saying that the company was “...advocating for an effective Carbon Border Adjusted Mechanism for Australia.” He also reconfirmed the group’s commitment to a target of net zero emissions by 2050. However, at the same time, Boral also reduced its emissions reduction target to 2025 from 2019 figures to up to 14% from 19% previously. This was blamed on “external factors” such as delays in securing the required regulatory approvals for the next phases of an alternative fuel program. Mining company Rio Tinto also warned in late July 2023, as part of its half-year financial results, that it might potentially miss its emissions target for 2025 unless it resorted to buying carbon credits.

CBAMs became serious in 2023 when the EU passed its own scheme into law in May 2023. The EU CBAM will now enter into a transitional phase from 1 October 2023 until the end of 2025. During this period importers of goods covered by the legislation will be required to report greenhouse gas emissions (GHG) embedded in their imports (direct and indirect emissions) but they will not have to make any financial payments or adjustments. The system will then enter its full format from 1 January 2026, with affected importers being forced to purchase and surrender CBAM certificates, which will be priced at the EU emission trading scheme (ETS) rate, currently at around Euro88/t. Other CBAMs have also been mooted in Canada and the US. In Canada the government ran a consultation on border carbon adjustments in 2021. It is currently considering its next steps. The US meanwhile has had both Republican and Democrat party senators make separate suggestions for a CBAM since at least 2021.

Just because the EU is set to implement its CBAM and other countries are considering their own versions doesn’t mean that they are necessarily a good idea. Cembureau, the European cement association, has been steadily lobbying on the details such as indirect emissions and waste incineration in the EU CBAM for years. Criticisms of CBAMs in general include potential clashes with World Trade Organisation rules, accusations of protectionism, triggering inflation, not being equitable to less developed nations and even failing to stop carbon leakage in the first place. The EU CBAM has also linked itself to the local ETS price. So, even after the transitional period, the carbon price may start to jump about in unpredictable ways once the system fully goes live in 2026.

The game-changer in recent years for international carbon emissions reduction legislation though was arguably when the US government introduced its Inflation Reduction Act in 2022. This is because it served both sustainability and self-interest on a grander scale than seen previously. The act promised US$369bn in subsidies for companies to invest in low carbon technology. However, the catch was that the investment tied supply chains to the US market, much to the ire of some of the US’ trade partners such as the EU. CBAMs offer a similar opportunity to governments around the world if they choose. They can be used to protect domestic carbon emission reduction effects in heavy industry but they can also be used for protectionism. Hence Bowen was due to say during his speech that the Inflation Reduction Act and other policies elsewhere “mean that Australia needs to act to stay in the game.” Australia has the advantage that it can watch how the EU CBAM pans out before it implements its own version.

Australia: The Ministry of Climate Change, Energy, the Environment and Water is holding a consultation over the possible implementation of a Cross-Border Adjustment Mechanism to penalise imported cement for its CO₂ emissions in line with the Australian cement industry’s emissions reduction goals. The Guardian Australia newspaper has reported that the government expects to publish its report on the policy in mid-late 2024. The government began implementing new CO₂ emissions limits for Australia’s 200 largest industrial emitters in July 2023. It expects these to eliminate 200Mt-worth of CO₂ emissions over the period up to 2030. Climate Change and Energy Minister Chris Bowen said “80% of these companies, and 86% of covered emissions, are covered by corporate net zero commitments.” Australia is committed to net zero CO₂ emissions by 2050.

With regard to the proposed Cross-Border Adjustment Mechanism, Bowen said “It’s a potentially important mechanism to ensure domestic sovereign capability and supply. One of the biggest challenges we face is supply-chain crunches, and any measure which helps us deal with that is a positive thing for the transition.”

US: UK-based Breedon Group says that it is seeking a ‘beachhead’ acquisition from which to build its own building materials business in the Eastern US. CEO Rob Wood said that the top 10 US building materials companies control 40% of the market there, compared to 75% of the UK market being controlled by five leading companies. The Times newspaper has reported that Breedon Group is due to join the UK’s FTSE 250 share index in September 2023. The producer noted the slow progress of proposed reforms to UK building standards, which it says would enable it to reduce its non-fuel CO₂ emissions by 25%. It also said that the government may fail to co-adopt EU emissions trading scheme (ETS) carbon border adjustment mechanism (CBAM) measures, leaving the UK market more open for third-party exporters of cement and other heavy materials.

Wood said “The North American market has big growth opportunities, backed by the certainty of infrastructure investment.”

The close of the first half of 2023 brought the latest crop of seasonal cement data from the Vietnam National Cement Association (VNCA). Vietnam sold 61.4Mt of cement and clinker during the first half of 2023, up by 2.7% year-on-year.¹ Graph 1 (below) tracks the progress of full-year Vietnamese cement and clinker sales over the six years up to 2022, as well as the most recent half-year.

Graph  1 - Vietnamese annual cement production, January 2017 – June 2023

The first half of 2023 marks the first half-year in which lockdown restrictions have been absent in both Vietnam and its main export market, China, since the start of the Covid-19 outbreak.² Vietnam was especially hard-hit: it implemented the first lockdown outside of China in March 2020, and has recorded the 13th most Covid-19 cases of any country up to July 2023. Then, the Russian invasion of Ukraine in 2022 caused uncertainties for cement producers and importers all around the world. Yet the price of imported coal across Southeast Asia had returned to pre-war levels by the end of June 2023.³ This indicates that the first half of 2023 may represent a ‘typical’ first half for the Vietnamese cement industry, for the first time this decade. During the 2010s, this meant growth margins of over 10% year-on-year.

During the first half of 2023, Vietnam’s sales volumes grew by 30% from pre-Covid-19 levels of 47.1Mt in the first half of 2019, confirming the industry trend of rapid capacity expansion. Just in the course of the half year, Vietnam’s integrated cement capacity rose by 7.9% to 123Mt/yr.⁴ It previously rose by 6.9% year-on-year to 114Mt/yr in 2022. That year, first-half cement sales also grew by 6.9% year-on-year, to 59.8Mt from 55.9Mt. In the first half of 2023, capacity growth has outstripped the country’s sales growth, of 2.7% year-on-year.

Meanwhile, Vietnam exported 15.7Mt of cement and clinker in the first half of 2023, 26% of its total despatches.⁵ This corresponds to a decline of 31% year-on-year from 22.7Mt (38% of despatches) in the first half of 2022 and a rise of 0.5% from pre-Covid-19 levels of 15.6Mt (33%) in the first half of 2019.

Chinese construction is the lynchpin in the Vietnamese cement industry’s current growth model. Over successive Five-Year Plans, it has consumed increasing volumes of clinker from Vietnam, as well as cement, at diminishing prices. This strategy overreached itself in the first quarter of 2023, more than a year into an on-going Chinese property market slump, when the value of Vietnam’s cement and clinker exports to the country fell by 95% year-on-year, to US$11.4m.⁶

By lowering prices, Vietnam’s cement sector charts a careful course within the contested waters of global trade rules, but it has run aground before. Most recently, from the start of 2023, the Philippines attached tariffs of up to 28% (and up to 55% for blended cement) to Vietnamese cement from 11 different producers.⁷ The Philippines Tariff Commission had found that ‘dumped’ cement from Vietnam – constituting over 50% of cement imports over the 18 months up to the end of 2020 – threatened the domestic industry. The failure to diversify its markets is a further sign that Vietnam’s current positioning in the cement and clinker trade is, at best, medium-term.

From October 2023, cement entering the European Union (EU) will become subject to extra taxes under the carbon border adjustment mechanism (CBAM).⁸ The EU is a relatively small trade partner for Vietnam, but the longer-term effect of this policy will be to replicate itself in the statute books of other nations and trade blocs, beginning in the Global North. With forecast lignite imports of 70 – 75Mt to Vietnam in 2023 – 2026, opportunities for cement exports from Vietnam, and countries like it, are diminishing.

The best situation for Vietnam would be accelerated growth in its domestic consumption base. The government is attempting to trigger a construction boom with its 2023 budget, which includes US$5bn in residential construction funding. Meanwhile, full-year infrastructure spending will rise by 25% year-on-year.⁹ To this end, it also needs to keep the cement price low. From 1 January 2023, Vietnamese exporters paid a tax of 10% of value on shipments of cement and clinker, instead of the previous 5% rate. If successful, this will nourish booming consumption with booming, and cheap, supply. Vietnam is grafting its Chinese model back onto the domestic market.

Producers will keep exporting. In May 2023, Nghi Son Cement Corporation despatched a first shipment of 31,500t of cement to the US. Nghi Son Cement Corporation’s cement, produced with fly ash, is clearly considered by the company and its owners to have some long-term marketability in the US. Said owners include Japan-based Taiheiyo Cement, which produces cement in the US via its CalPortland subsidiary.

In Vietnam, the cement industry has undergone a period of unparalleled growth, fuelled by exports. It can now reinvest the proceeds in establishing a self-sufficient construction sector around an ever more sustainable cement industry, ready to become the first choice across new markets as they arise in Southeast Asia and beyond.

1. Global Cement, 'Vietnam's first-half cement production declines in 2023,' 29 June 2023, https://www.globalcement.com/news/item/15941-vietnam-s-first-half-cement-production-declines-in-2023

2. The Observer, ‘‘It was all for nothing’: Chinese count cost of Xi’s snap decision to let Covid rip,’ 29 January 2023, https://www.theguardian.com/world/2023/jan/29/chinese-cost-covid-xi-lockdowns-china

3. Reuters, ‘Column: Asia thermal coal prices get the blues from Europe and LNG,’ 20 June 2023, https://www.reuters.com/markets/commodities/asia-thermal-coal-prices-get-blues-europe-lng-russell-2023-06-20/

4. Việt Nam News, ‘Record input costs thwart cement groups,’ 12 July 2023, https://global.factiva.com/ha/default.aspx?mod=SavedSearch_SelectSearch&page_driver=SavedSearch_SelectSearch#./!?&_suid=168119771197707004455190223307

5. Việt Nam News, ‘Industry: Vietnam’s Cement, Clinker Exports +82.2% y/y to $116M in Jun: GSO,’ 4 July 2023, https://global.factiva.com/ha/default.aspx?page_driver=searchBuilder_Search#./!?&_suid=168908188871006418595282713178

6. Vietnam Investment Review, ‘A strenuous year ahead in cement,’ 9 May 2023, https://vir.com.vn/a-strenuous-year-ahead-in-cement-101707.html

7. Global Cement, 'Philippines Department of Trade and Industry to impose anti-dumping duties on cement from Vietnam,' 22 December 2022, https://www.globalcement.com/news/item/15084-philippines-department-of-trade-and-industry-to-impose-anti-dumping-duties-on-cement-from-vietnam

8. Global Cement, 'Too taxing? How the CBAM affects cement exporters to the EU,’ 29 June 2022, https://www.globalcement.com/news/item/14316-too-taxing-how-the-cbam-affects-cement-exporters-to-the-eu

9. Customs News, ‘Cement enterprises expect a "brighter" second half of 2023
https://english.haiquanonline.com.vn/cement-enterprises-expect-a-brighter-second-half-of-2023-25368.html

Taiwan Cement said this week that it is aiming for cement to account for less than half of its sales by 2025. At the annual shareholders’ meeting chair Nelson Chang defended the cement sector as a core business but said that the company was expanding more into the green energy sector through its energy storage and vehicle charging lines. Chang directly linked the strategy to growing carbon taxes around the world, such as the European Union Emissions Trading Scheme, where the carbon price has been occasionally close to pushing past Euro100/t since early 2022. Taiwan Cement formed a joint venture with Türkiye-based Oyak Group in 2018 that runs Cimpor in Portugal.

Table 1: Cement business share by revenue of selected cement producers. Source: Corporate annual reports.

Taiwan Cement’s plan to decrease its reliance on cement is becoming a familiar one. Holcim notably revealed in 2021 that it was growing its light building materials division. Its cement division represented 60% of sales in 2020 with concrete and aggregates making up most of the rest to 92% and the remaining 8% on other products including light building materials. This started to change with the acquisition of roofing and building envelope producer Firestone Building Products in 2021. Other similar acquisitions have followed. Holcim’s current target is to grow the Solutions & Products division to around 30% by 2025, with cement reduced to somewhere between a third and half of sales. Earlier this year Japan-based Taiheiyo Cement said it was doing a similar thing as part of its medium-term strategy to 2035. In its case cement represented 70% of its sales in 2022 but it is now aiming to reduce this to 65% by 2025 and 50% by 2035.

A common pattern for the business composition of European cement companies is a mixture of heavy building materials made up of cement, concrete and aggregate. However, not every cement company follows the same route. Some cement companies are simply parts of larger conglomerates. UltraTech Cement, for example, is mostly just a cement company. However, it is also part of Aditya Birla Group, which runs a wide range of industries including chemicals, textiles, financial services, telecoms, mining and more. Depending on how one looks at it, UltraTech Cement’s cement business ratio is large or Aditya Birla Group’s ratio is small. Siam Cement Group (SCG) in Thailand is another example of a cement producer operated by a conglomerate with other major businesses.

A different approach that some cement producers take is to mix cement production with complimentary businesses outside of heavy building materials. A good example of this is Votorantim Cement in Brazil, which manufactures cement and steel. Companhia Siderúrgica Nacional (CSN) is another Brazil-based cement producer that is also well known for steel production. Adani Group in India, meanwhile, was well known for logistics, power generation and airports before it purchased Ambuja Cements and ACC from Holcim in 2022.

The driver for cement companies looking to reduce cement as a proportion of their businesses has varied between the three examples presented above. Holcim’s approach has been in response to growing European carbon costs but it also fits with a general desire to broaden its business as the company has sought to reshape itself following the merger between Lafarge and Holcim. Taiheiyo Cement’s plans also have a sustainability angle but the Japanese market has been in slow decline since the 1990s and this has been made worse by the spike in energy prices since 2022. Investing in new businesses makes sense for either of these reasons. Lastly, Taiwan Cement says it is taking action in response to carbon prices around the world. However, its proximity to many other large-scale producers in the Far East may also be a factor. Whether more companies follow suit and also start to reduce the ratio of their cement businesses remains to be seen. Yet, mounting carbon taxes and global production overcapacity look set to make more of the larger cement producers consider their options in certain places.

Australia: Adbri reported a full-year rise in sales of 8.5% year-on-year to US$1.15bn in 2022 from US$1.06bn in 2021. Its earnings before interest and taxation (EBIT) fell to US$106m, down by 10% from US$118m. The producer said that its cement sales rose by 6.3% year-on-year. Demand remained ‘solid’ in Western Australia, while sales dropped in Southern Australia, partly due to wet weather and the loss of an exclusive supply contract. Adbri noted that “The backlog of residential construction works, attributed to the shortage of trades and wet weather in 2022, will continue to underpin good order books in 2023.”

The group said “The past year has been one of the most challenging for the company in its long history. Our results were delivered against the backdrop of a difficult macroeconomic environment, which included the global economic instability resulting in inflationary pressures and wet weather events across Australia. The company also underwent a substantial leadership transition in the latter part of the year, with the former managing director and chief executive officer (CEO) and chief financial officer stepping down from active duties as the company accelerates its transformational agenda.”

In 2022, Adbri achieved a 12% reduction in operational CO₂ emissions compared to 2019. Chief executive officer Mark Irwin called on the national government and state governments to embed CO₂ emissions reduction targets in legislation, and on the former to implement a carbon border adjustment mechanism on imported cement. Irwin noted that failure to implement such measures may lead lower-emitting plants such as the Birkenhead, South Australia, cement plant to transition to grinding imported clinker or consider closure.

Australia: The government plans to reform its CO₂ emissions Safeguard Mechanism in line with its stated goal of net zero CO₂ emissions by 2050. Under the latest proposals, 215 industrial plants, including Australia's cement plants, will have to reduce their CO₂ emissions by 4.9% year-on-year every year until 2030. The Australian newspaper has reported that the government is currently receiving submissions on the proposed reform as part of its consultation process, which will end on 24 February 2023.

The Business Council of Australia and the Australian Industry Group have encouraged the government to introduce an adjustment mechanism for imports, based on the EU's Carbon Border Adjustment Mechanism (CBAM), in conjunction with any tightening of the Safeguard Mechanism.