
Take: CBAM and International Credits: What’s Just Changed? - with Dan Maleski
Take on a podcast episode from The CDR Policy Scoop, originally published Fri, 15 Ma. Listen: https://shows.acast.com/the-cdr-policy-scoop/episodes/cbam-and-international-credits-whats-just-changed-with-dan-m TL;DR Draft Carbon Border Adjustment Mechanism implementing act (published 13 May 2026) lets importers deduct carbon costs paid abroad — including, controversially, international credits. First-time clarity worth knowing. Hard cap: international Article 6 credits can offset at most 10% of a CBAM liability. But most third-country ETSs already cap offset use at 5-10%, so binding impact is modest. No quantitative cap on domestic credits used inside a third-country mandatory regime. Maleski can’t justify the asymmetry; nor can the hosts. Genuinely odd policy choice. “Effective” carbon cost is net of free allocation — so Brazil, Turkey, Korea ETSs in ramp-up phase deliver near-zero deduction regardless of headline carbon price. Important reality check. Anti-gaming safeguard is “independent persons” verifying paid prices. Maleski openly notes clients ask how to inflate intra-group credit prices. Thin guardrail. The CDR Policy Scoop (episode link) reconvened Dan Maleski of Ruby Advisors one day after the Commission dropped its draft implementing act on Article 9 of CBAM — the provision letting importers deduct carbon costs already paid in the country of origin. Sebastian Manhart and Eve Tamme spend 30 minutes parsing what the act actually says about international credits, the 10% cap, and why the consultation (closing early June) still leaves big pieces missing. ...








