Article 27a in the European Commission’s proposal would empower the Commission to trigger a temporary suspension due to so-called “serious and unforeseen circumstances” related to the prices of goods.
We propose to remove this article. This is because the more industries we speak to, the more it becomes clear that this clause would be detrimental to investment certainty for low-carbon solutions in Europe. We therefore call it the “game-over clause” for the CBAM.
Investor certainty depends on all sectors remaining predictably covered by the CBAM. Therefore, it must not be possible to remove any goods from the scope, even temporarily. Retroactively removing goods would be even more damaging, as it would further reduce investor certainty and undermine the CBAM’s effectiveness. Allowing goods to be removed risks weakening incentives to invest in clean alternatives and puts a break on Europe strategically increasing its competitiveness in a decarbonising world.
See also: Joint industry letter calling on EU leaders to remove Art 27a (February 2026)
About the Business for CBAM Coalition
The Business for CBAM Coalition brings together businesses and business associations committed to upholding the ambitions of the Carbon Border Adjustment Mechanism (CBAM) and consequently of the EU Emissions Trading System (ETS). These policies are essential – not only for the EU’s path to cost-effective decarbonisation, but also for securing the long-term competitiveness of European industry in a rapidly evolving global economy.
Contact the secretariat via info@businessforcbam.eu