Policy brief

Read the regulation, implementing acts and guidance article by article, size the impact from public data and set out each side's position. Every claim cited, every uncertainty flagged

Customize this Agent

DOCXXLSX12 steps

The problem

Definitive period since 1 January, default values corrected in July, guidance out in August

Multiply embedded emissions by the ETS price and the 2026 bill is overstated: importers are credited the free allocation EU producers still receive, which the CBAM factor holds at 97.5 percent this year. Use default values without the 2026 mark up, or add indirect emissions to steel and aluminium, and the estimate is wrong again

The request

Write a policy brief on the CBAM definitive period for trade and climate policymakers weighing the downstream extension and export treatment. Work from Regulation 2023/956 as amended by 2025/2083, implementing acts and Commission guidance: what changed on 1 January 2026, for whom, by article. Estimate what 2026 iron and steel, aluminium, cement and fertiliser imports will owe for each sector and its top five origins, from Comext, default values, benchmarks and certificate prices, and EU producers' lost free allocation on exports. Show the method in a workbook. Set out published positions of EU producers, importers, exporting countries and NGOs, including on downstream. Four pages at most with options, tradeoffs, recommendations and an origin annex. Cite every claim, mark anything uncertain.

How Axe works

ApprovedChanges asked

Your reviewApprove, or say what to change

Approved or changes

Brief and workbookBrief, workbook and fact check

Final reviewApprove the revised files

Revised brief and workbookRevised files and fact check

Step

Size the impact

Prompt

Sent to the model at this step

Estimate what 2026 imports of iron and steel, aluminium, cement and fertilisers will owe in CBAM certificates. Take tonnes by Annex I CN code and country of origin from Eurostat Comext. Fill months not yet published two ways, with the same months of 2025 and with the 2026 run rate to date, mark both as estimated and carry both through. In each sector keep the five largest origins by tonnage and group the rest. Apply the country default values in Implementing Regulation (EU) 2025/2621 as corrected by 2026/1740, with the 2026 mark up of 10 percent, or 1 percent for fertilisers. Count only direct emissions for iron and steel and aluminium, and direct and indirect emissions for cement and fertilisers. Deduct the free allocation adjustment under Implementing Regulation (EU) 2025/2620: the default CBAM benchmark for the production route the default value assumes, times the 97.5 percent CBAM factor, times the 2026 cross sectoral correction factor. Price each quarter's imports at that quarter's certificate price: the published prices for the first and second quarters; for the third, the volume weighted average of EU ETS auction clearing prices from July to September, as the Commission calculates it; for the fourth, the December 2026 EUA future on the as of date. If either cannot be retrieved, ask me for it, and mark both as estimates until the Commission publishes. Leave out any deduction for a carbon price paid abroad until its implementing act is adopted, and say so. Reduce the result by the Commission's estimate that the 50 tonne threshold exempts 0.87 percent of embedded emissions, published 30 September 2026 for April 2025 to March 2026, after confirming it on the Commission's site; if it cannot be confirmed, leave it out and say that trade data cannot separate importers below the threshold. Then estimate export leakage: EU exports of the same goods from Comext, times the benchmark, times the share of free allocation the 97.5 percent CBAM factor removes this year, priced the same way, because those exports carry no CBAM cover. Show tonnes, gross emissions, the adjustment, net certificates and euros for each sector and origin, the export leakage by sector, a sensitivity to the certificate price, and a case with verified emissions at the benchmark to show what default values cost. Put the method and every parameter, with its source, on its own tab.

Uses

Scope
As of date
Materials
Provisions

Produces

Impact model

What you get back

DOCXPolicy briefKey points, background, analysis, implications, options and recommendations, footnoted, with an origin annex

XLSXImpact workbookProvisions by article, imports, cost by sector and origin, export leakage, sensitivities and positions

Fact checkOpen items first, then each claim marked checked or corrected, with its source

Make it yours

Point it at another regulation, change the sectors and origins you size, or set your house format for the brief. Every step and every prompt can be edited

Customize this Agent

Opens a private copy of this Agent in your workspace, ready to adapt to your own sources

More agent examples

Sovereign debt economistsDebt sustainability analysisDOCXXLSX16 steps

Program evaluatorsProgram evaluationDOCXXLSX16 steps

Capital markets analystsBroker opinion of valuePPTXXLSX16 steps

Financial planning analystsBudget variance analysisXLSXDOCX13 steps

Credit research analystsCapital structure analysisXLSX12 steps