#19 Pauline Miquel - The Surprising Complexity of Implementing CBAM: Monitoring, Verification, and Real Costs

February 24
50 mins

Episode Description

The EU’s Carbon Border Adjustment Mechanism (CBAM) is designed to level the playing field: if EU producers pay a carbon price under the EU ETS, importers should face a comparable price at the border—adjusted for any carbon price already paid abroad. 

But turning that logic into a working system requires something the EU doesn’t naturally have for global supply chains: credible, product-level emissions data, verified across jurisdictions.

In Episode #19, I’m joined by Pauline Miquel, a policy expert who has been tracking CBAM’s fast-moving details and its implications for importers (especially in steel supply chains). 

We discuss:

  • What CBAM covers first (cement, steel, aluminium, hydrogen, electricity, fertilizers—and even some downstream products) 
  • Why the end of 2025 brought major last-minute changes—especially around default values that can materially raise expected costs 
  • The “ETS logic,” but globally: how third-party verification is supposed to work when emissions are embedded across fragmented supply chains 
  • Key uncertainties for importers: timing, predictability of liability, and the shift from quarterly to annual reporting 
  • A technical detail that matters: the benchmark (reflecting remaining free allocations under the ETS) and why it can move costs substantially 
  • Why CBAM is ultimately a procurement + finance + contracting problem—not just a sustainability reporting line item 

For questions, comments or suggestions, you can contact me at arvid.viaene.ce@gmail.com

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