By Climate Leadership Council
Originally Published May 19, 2026
The Climate Leadership Council submitted comments on the draft regulations for the UK’s Carbon Border Adjustment Mechanism (CBAM), welcoming it as a meaningful step in trade-based climate policy while flagging a critical design flaw: the proposed use of global default values for embodied emissions.
This approach undermines carbon leakage prevention, disadvantages cleaner producers including U.S. manufacturers, and sets a poor precedent as more countries develop their own border adjustment policies. Instead, the Council recommends country-specific default values based on average emissions intensity by country