CBAM: Were the Specific Embedded Emissions Produced by EU NGOs?
CBAM: Were the Specific Embedded Emissions Produced by EU NGOs?

20 November 2025 – Is the European Commission letting politically motivated industry associations do its work on CBAM? Were the Country Specific Embedded Emissions for steel created exclusively from data provided by European non-governmental organisations? In Romania, a potential case of fraud involving EU ETS certificates at a steel plant has been uncovered.

CBAM: Were the Specific Embedded Emissions Values Produced by EU NGOs?

As we were able to learn yesterday, the European Commission apparently relied exclusively on data from European non-governmental organisations when compiling the currently circulating table of Country Specific Embedded Emissions for steel. More precisely, from the associations worldsteel (based in Brussels, Belgium), EUROFORGE (based in Brussels, Belgium), and CAEF – The European Foundry Association (based in Düsseldorf, Germany).

Weak data basis even for the steel industry association?

A look at the general CO2 data published by worldsteel shows that the supposedly very high values for certain origins simply cannot be correct. Moreover, worldsteel only began collecting this data (GHG emissions intensity, tonnes CO2e per tonne of crude steel) in 2024. And only a fraction of steel producers participated in the data collection, meaning that many of the origin values were most likely simply constructed.

Source: worldsteel Sustainability Indicators Report 2025
Source: worldsteel Sustainability Indicators Report 2025

Commission lets politically motivated NGOs work on its behalf

Once again, this is an excellent example of how the Commission conducts politics through the back door. Instead of relying on valid, scientifically obtained data, the Commission leans on data collected by politically motivated NGOs and supposedly published publicly. This reinforces market rumours that the Commission neither before the launch of CBAM nor during the CBAM test phase was able to gather sufficiently reliable CO2 data on which to calculate the embedded emissions.

So instead, they continue to rely on fantasy data that was likely inflated by the steel associations. The cost of their own failure with the CBAM CO2 tax is once again being passed on to European companies.

This calls to mind the still unresolved scandal concerning NGO influence on the EU Green Deal that was funded by the Commission.

Possible fraud case involving EU ETS certificates in Romania

The Romanian public prosecutor’s office is investigating possible fraud involving CO2 certificates at the Liberty Galați steel plant. They suspect that company executives may have embezzled funds and carried out fictitious transactions to benefit affiliated companies.

If the allegations are confirmed, this would be far from the first fraud involving EU CO2 certificates since the introduction of emissions trading in Europe – and not the largest case either. In total, the damage caused by fraudulent behaviour involving ETS certificates amounts to several billion euros.

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