The relevance of ResponsibleSteel standards to the implementation of climate policies such as CBAM

The trade in goods and associated supply chain greenhouse gas (GHG) emissions have become more prominent in climate policy discussions over recent years. Intensive negotiations at COP26 on nationally determined contributions (NDC) are of course essential, however, trade in goods between countries and continents does somewhat complicate the question of who is responsible for production emissions. Whilst many countries have signed up to a net zero target by 2050, their NDCs don’t include the often rising amount of embodied emissions from imported goods. An opportunity for countries to support each others’ efforts to reduce their own emissions, for mutual benefit, is being missed.

A recent report on counting carbon in global trade suggests that as much as 38% of global emissions emanate from traded goods, meaning that countries are very much interconnected in the global fight to reduce GHG emissions. Whilst there is no standardised global accounting method for measuring embodied emissions in traded goods, proposals are already afoot to take these emissions into account in new climate policies.

Several countries, including the EU and US, have recently announced plans to introduce a form of carbon border adjustment mechanism (CBAM) with the intention to ensure a level playing field when it comes to the climate compliance costs of manufacturing. Also related specifically to steel, the United States and the European Union have just committed to “negotiate a carbon-based arrangement on steel and aluminium trade…to address carbon intensity of steel… ….and to encourage the production and trade of low-carbon steel.” (White House briefing 31st October 2021).

A CBAM goes some way towards introducing, and partly incorporating, the externality cost of carbon emissions into the price of purchased products. Some industries would argue that they have to absorb higher climate compliance costs when operating in regions such as the EU, which operates an emissions trading scheme, compared to some of the countries exporting to the EU. The border adjustment seeks to make a tax adjustment at the border when goods are imported from a country that enjoys relatively lower compliance costs. Part of the proposed approach by the EU includes having to measure the embedded emissions (in tonnes of CO2e per tonne) of the product that is being imported, and this is where standards, verification and certification come in.

WTO rules make provision for countries that wish to take steps on domestic environmental protection and conservation, and can make reference to international standards. ResponsibleSteel has spent considerable time with its member organisations and other steel sector stakeholders in developing an international standard incorporating rules for the consistent measurement and reporting of the GHG emissions intensity of steelmaking. The standard covers scope 1 and 2 emissions, and crucially the upstream scope 3 emissions for crude steel production. The EU CBAM proposal looks to be very similar in its approach but will also extend to more processed downstream steel products. The existing and developing carbon measurement methodologies in the steel sector, such as those proposed by ResponsibleSteel (for steelmaking sites) and the Net Zero Steel Pathway Methodology Project (at the corporate level), should contribute towards a basis for a common assessment method and setting the right system boundaries under a CBAM policy. At the very least, companies that measure and benchmark their product GHG emission intensities through ResponsibleSteel, will be in a better position to assess the implication of a CBAM on their markets.

Michael Liebreich goes into more details on the issues already mentioned and sets out the characteristics on an effective CBAM. Whilst the primary aim of CBAM is to create a level playing field, or as critics claim as a protectionist measure, time will tell as to the potential wider implications of climate polices such as CBAM in incentivising climate action in, and diverting finance towards, low GHG steelmaking technologies, not only in more developed nations but also in developing countries that may be at earlier stages of their decarbonisation journey.

Either way, we believe that ResponsibleSteel international standard has a critical role to play in providing a globally consistent, verifiable basis for comparing the GHG emissions intensity of steelmaking at different sites around the world.