One of the big differences from the leaked draft(s) seems to be that during the transition phase importers would now not have to pay a CBAM levy, but instead just meet a list of reporting requirements:
I say “just” … but you know what I mean.
As per the leaked drafts, UK imports not [currently] exempt from the CBAM.
One of the big differences from leak one [but not leak two] is that this won't be administered by one centralised CBAM authority, but rather by "competent authorities" in each member-state.
Which is how these sort of things normally work within the EU, tbf.
Another difference from leak one [but not leak two] is that a competent authority will repurchase no more than "one third of the total" excess CBAM certificates at the end of each year. [First draft limited this to 10% of total purchased].
Anyway, enough from me - I'm off to retrain as an "accredited verifier" and make my millions.
Wait, scrap that. Involves hard maths.
OH I'VE FOUND A BIG CHANGE
The leak from earlier this week [left] said that the CBAM regulation falls within the scope of the Northern Ireland Protocol.
The official proposal [right] ... does not mention the Northern Ireland protocol.
🤔
What is going on here? IT IS A MYSTERY.
I mean, I’m pretty sure it is in scope. But I guess not saying it is in scope now at least means we don’t have to discuss what it being in scope actually means on practice until later on when everyone suddenly realises it is in scope. Which is probably wise, tbf.
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The EU’s new CBAM regulation probably should fall within the scope of the NI protocol, in order to prevent carbon-intensive imports dodging the new levy by entering the EU market via NI.
However, it is not clear how this would function in practice.
AND … going off today’s leaked impact assessment, we assumed correctly.
These are some of the considerations/options that the EU will need to take into account in respect of its carbon-border adjustment mechanism (CBAM) and Northern Ireland:
So unless I’m misunderstanding the UK-Australia AIP, it’s not actually duty and quota free. Long-grained milled rice being the last bastion of protectionism:
A related story: When Raab banned UK officials from attending EU meetings in the run up to Brexit, Scottish officials kept going to some anyway.
On the UK presenting a united front thing, another related story: I remember witnessing a load of ERG MPs turn up in Warsaw in a last ditch attempt to convince the Polish government to veto any UK request to extend article 50.