22.08.2025

ORLEN position in public consultations on the revision of the Regulation establishing a carbon border adjustment mechanism (CBAM)

ORLEN presented its position as part of the European Commission public consultation on the planned revision of the Regulation establishing a carbon border adjustment mechanism (CBAM).

The company highlighted the main challenges associated with extending CBAM to downstream goods and emphasised the need to provide additional measures preventing circumvention of the regulation. Extending the CBAM to cover additional goods, particularly downstream products is important and necessary but it should be carried out carefully and evidence-based. ORLEN call for a careful, phased approach and avoidance of fragmented measures that could undermine regulatory predictability and the integrity of the EU market. The impact of any possible CBAM extension must be thoroughly assessed in cooperation with the sector concerned. It is crucial that measures to prevent the circumvention of CBAM are proportionate and feasible, and are based on a sound risk analysis. ORLEN once again called for measures ensuring a level playing field for European industries exporting their goods outside the EU. Replacing existing mechanisms preventing carbon leakage (free allocation and compensation of indirect carbon costs) with CBAM without adopting additional export measures would weaken European industry and would  lead to a carbon leakage.

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