Comments in Response to the European Commission's Consultation on a Carbon Border Adjustment Mechanism

The Chamber is a longtime advocate for stronger commercial ties between the United States and the European Union. According to a recent Chamber study, the U.S. and EU are together responsible for more than 40% of global gross domestic product, and transatlantic trade and investment support 16 million jobs on both sides of the Atlantic. In the U.S. and globally, we advance cost-effective policy frameworks, informed by science, that support economic growth, promote consumer protection, foster innovation, and advance our members’ sustainability priorities.

The Chamber recognizes that a robust sustainability strategy—as outlined in the European Green Deal—is a central pillar of the Commission’s agenda. We believe sustainable growth requires a vigorous dialogue between policymakers and the private sector to make our societies more prosperous and resilient and to address the many environmental challenges arising from human activity. We also believe sustainability policies must be consistent with countries’ international obligations.

The Commission’s consultation document includes several detailed questions concerning design and implementation of a CBAM. The Chamber has not responded to these in detail; instead, we identify several critical issues that should be borne in mind as the Commission develops any such proposal. Please find the Chamber's comments linked above.