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26.08.2025

CBAM and Market Coupling: Key Considerations for Electricity Markets

We welcome the opportunity to contribute to the European Commission’s call for evidence on the implementation of the Carbon Border Adjustment Mechanism for electricity.

As stakeholders actively engaged in the integration and decarbonisation of European electricity markets, we wish to share our insights on the critical interplay between CBAM and implicit market coupling. Our contribution highlights key challenges, unintended consequences and areas requiring further clarification – particularly with respect to electricity pricing, market stability and regulatory certainty.

We submit the attached considerations and recommendations to support a more effective and coherent implementation of CBAM within the evolving framework of the Internal Energy Market.