Cases - BACC

Launching the Business for CBAM Coalition

Political Context

Alongside the EU ETS (ETS1), the Carbon Border Adjustment Mechanism (CBAM) is the most important piece of EU climate and trade policy of the last decade, and it is now under serious political pressure. I saw the need for a Coalition of businesses that could provide a positive counter-voice to those that wanted to water down the ETS1 and CBAM.

Testing the Demand

I wanted to make sure that Coalition was built on demand rather than assumption, so I started by testing the idea with companies and with policymakers in my network. Both sides said the same thing: there was space for a dedicated, business-led voice on CBAM, and there was appetite in the institutions to engage with one.

Rebuilding Visibility

To rebuild visibility around these files and around my own work on them, I ran two educational public webinars in the months before launch. The first, in June 2025, covered the ETS1 in partnership with an influential think tank. The second, in August 2025, focused on the potential future revisions of CBAM. Both drew audiences from well beyond Brussels and helped re-establish me as a go-to voice on these questions, which made it far easier to bring partners on board when the Coalition launched.

Building the Launch

The launch event itself required months of careful groundwork, both on content and on political choreography. Getting MEP Peter Liese (former ETS1 Rapporteur), MEP Mohammed Chahim (former CBAM Rapporteur) and a representative of Climate Commissioner Hoekstra’s cabinet into the same room around an early-mover business agenda took persistent, early-stage engagement with each of their teams.

Launch & Positioning

On the day of the launch event, my team and I also made sure that the brand-new website of the Coalition was filled with short, practical positions on the hot-potato items of both climate files. The event was a full house, featured several media-worthy sound bites from the key EU policymakers present, and set the Coalition up with the profile and institutional relationships it needed from day one. Some of the Coalition’s highlights include:

Almost 60 meetings so far with national ministries, Members of European Parliament (MEPs) or their teams, and European Commission staff.
Participation in the October 2025 high-level CBAM Dialogue with Executive VP Séjourné and Commissioner Hoekstra, as well as the May 2026 high-level roundtable on ETS1 with DG CLIMA Director General Kurt Vandenberghe.
Coordination together with partners Cleantech for Europe, the We Mean Business Coalition, and the Corporate Leaders Group Europe of a pro-ETS1 letter addressed to Heads of State signed by 150 companies and investors.

The Business for CBAM Coalition is now the first major project I am bringing into BACC.

Securing a level playing field in the EU Hydrogen Bank’s second auction

Policy Context

The European Commission set up the EU Hydrogen Bank in 2023 to kickstart production of home-grown renewable hydrogen in Europe. The first auction, concluded in early 2024, made it clear that a large share of winning projects intended to source their electrolysers from outside the EU, and predominantly from China. Without a course correction, the Hydrogen Bank risked subsidising the displacement of Europe’s own electrolyser industry at the very moment that industry was scaling up.

Strategic Objective

I led the work for an early-mover electrolyser manufacturer that wanted the second auction to be designed differently. Our objective was specific and time-bound: a resilience criterion in the second auction’s terms and conditions that would limit the share of electrolyser components sourced from countries with state-subsidised, closed markets. With the second auction call expected later that year, we had a narrow window to act in.

Building the Case

The case rested on facts the Commission was well placed to recognise but had not yet operationalised in Hydrogen Bank rules. Chinese electrolyser manufacturers benefit from extensive state support and operate in a domestic market that is effectively closed to European suppliers, while Chinese production capacity already exceeds half of global supply. We anchored our argument in independent analysis, including the TNO and HCSS report on Europe’s dependence on China across the wind and broader clean energy supply chains, and translated those findings into concrete legislative language for the auction’s design.

Institutional Engagement

We then ran a deliberate sequencing of engagement. Early outreach to the highest levels of the European Commission helped escalate the issue and unlock access across the institution. Over the following months my team and I helped the client speak to around ten cabinets and Directorates-General, walking decision-makers through the evidence and the proposed design fix. We also worked with others in the renewable hydrogen value chain to make sure the proposals reached the Commission from multiple voices.

Outcome & Impact

The outcome was published on 25 September 2024 in the second auction’s Terms and Conditions. This second auction worth EUR 1.2 billion now required that projects “limit the sourcing of electrolyser stacks with surface treatment or cell unit production or stack assembly carried out in China to not more than 25% (in MWe),” on the explicit grounds that the EU faces “a significant risk of increased and irreversible dependency” on Chinese electrolyser imports that “may threaten the EU’s security of supply.”

For the first time, the Hydrogen Bank’s design now treats European electrolyser manufacturing capacity as a strategic asset to protect against unfair competition elsewhere, not just a cost to optimise. This non-price auction criterion shaped the outcome of more than a billion euros in auction revenues. It also set an important precedent: EU legislation is increasingly becoming more reciprocal to protect European cleantech industries against unfair competition.

Rewiring ETS free allocation for early movers in heavy industry

The Challenge

Free CO2 permits under the EU’s Emissions Trading System (ETS1) are a well-known tool to protect heavy industry against carbon leakage. However, back in 2020, the way these free CO2 permits were distributed (based on a system called ETS product benchmarks) was one of the least-watched corners of EU climate policy. Several ETS product benchmarks were built around outdated production processes, which meant early movers using cleaner technologies fell outside the benchmark and received little to no free allocation, while higher-emission routes remained comfortably covered.

For example, the Hydrogen benchmark covered only fossil-based production, meaning a company investing in renewable hydrogen would exit the ETS1 and lose its free allocation. The Sintered Ore benchmark only covered iron ore producers making CO2-intensive sintered ore fines, while cleaner iron ore pellet producers were pushed into the fallback benchmarks and received a fraction of the free allocation per tonne of iron ore that their higher-emission peers received. The whole logic was backwards.

Building The Coalition

When my team and I started speaking to EU policymakers about this issue back in 2020, they acknowledged the problem but said they could not undertake action until we showed it was something holding back clean innovations across several industries and countries. My job was therefore to turn this technical issue into a cross-industry story that EU policymakers could engage with. I brought together and coordinated an informal coalition of early movers across iron, steel, cement, hydrogen and power, and together we worked the file at three decisive moments:

Over roughly a year of monthly meetings, I worked with other expert group members to build the case for technology-neutral benchmarks, and prepared technical submissions on several of them. Where the analysis pointed in a different direction from other contributions, we set out the data: that new and legacy production techniques competed for the same markets, and that inputs for cleaner production were available at a scale relevant to the whole sector.

The Outcome

The outcome, published in the EU Official Journal on 4 April 2024, fundamentally reshaped how free allowances are distributed across several key benchmarks. In the iron ore sector alone, I helped revise the main ETS benchmark in such a way that around 9 million free CO2 permits per year would shift away from higher-emission iron ore routes, and up to 3 million additional free permits per year would flow to clean iron ore producers over 2026 to 2030. In addition, breakthrough technologies such as renewable hydrogen now qualify for free allocation for the first time. All in all, a win-win for the climate and for sustainable business cases.

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