The Association of German Chambers of Commerce and Industry (DIHK) advocates for a rapid overhaul of the European CO₂ border adjustment mechanism (CBAM). Feedback from entrepreneurial practice indicates that many businesses struggle with high bureaucratic efforts, rising costs, and a lack of planning security. Without adjustments, there is a threat of competitive distortions, supply chain shifts, and a gradual loss of industrial value creation in Europe. The feedback comes predominantly from industry, trade, and logistics.

"Companies are already under significant pressure due to challenging location conditions, high costs, and increasing trade barriers. European climate protection ambitions must not exacerbate these burdens further. However, this is exactly what many companies are currently experiencing with the CO₂ border adjustment," says Melanie Vogelbach, Head of International Trade Policy at the DIHK.

From the perspective of the DIHK, effective protection against so-called carbon leakage is indispensable. This refers to the relocation of production to countries with less stringent climate protection requirements. Energy and resource-intensive industries, in particular, need fair competition to maintain investments and value creation within Europe. "Climate protection and competitiveness must go hand in hand. Europe must not risk production and investments migrating to other locations. For this, fair competition is necessary," emphasizes Vogelbach.

The DIHK is especially critical of the still missing solution for exports. While certain basic material imports into the European Union are burdened with a CO₂ price, these increased input costs undermine competitiveness in downstream value chains on global markets. Providers from countries without comparable CO₂ costs have a clear advantage here. Furthermore, the CO₂ border adjustment must be closely coordinated with other industrial policy initiatives of the European Union, such as measures to protect the steel industry and the planned Industrial Accelerator Act. "A major design flaw of the CBAM is the lack of an export solution. European companies must not be sent into global markets with additional burdens while their competitors do not face these costs," Vogelbach states.

The burdens now extend far beyond the basic material industries. Downstream value chains, trade companies, and export-oriented SMEs are also affected. Many companies report additional documentation requirements and significant implementation efforts. "Companies do not need a further spiral of regulation. Those who want to shape climate protection effectively must limit bureaucracy and take international competitiveness into account. SMEs, in particular, need practical and reliable rules," Vogelbach adds.

Therefore, the DIHK calls on the federal government and the EU Commission to structure standard values more realistically, extend certification deadlines, and fundamentally simplify proof chains. Future expansions of the system must be based on SME-friendly, practical processes. Above all, a viable export solution is urgently needed swiftly. "The transformation will only succeed when it remains economically viable. Europe must lead in climate protection – but not become the location with the highest burdens," warns Vogelbach.

Further information and the DIHK impulse paper "CBAM Challenges 2026" available for download here.