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