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VI. Environment & Climate

Carbon border taxes: climate tool or green protectionism?

Query: carbon border adjustment mechanism CBAM developing countries exports competitiveness green protectionism carbon pricing trade

Timeline As of 2024
WBG (World Bank Group)
2010

Cautiously open to carbon border adjustments to curb leakage, but warned of WTO incompatibility, green protectionism risks, and harm to developing countries' exports.

In 2010, the World Bank Group acknowledged carbon border adjustments as a potential tool to address carbon leakage and protect the competitiveness of energy-intensive industries in high-income countries, but raised significant concerns about their compatibility with WTO rules, risks of green protectionism, and adverse implications for developing countries' export competitiveness. It noted legal uncertainty around unilateral border tax adjustments on embodied carbon, highlighted the unresolved question of revenue use, and emphasized that exemptions for developing countries—while politically and equitably motivated—risk enabling carbon leakage. The Bank cited empirical trends suggesting possible relocation of carbon-intensive production to unregulated jurisdictions, yet stressed that evidence remained inconclusive and that developing countries were still net importers of such goods.

IMF (International Monetary Fund)
2021

Views CBAM as a potentially legitimate climate tool against carbon leakage, but warns it risks green protectionism and trade harm to developing countries without adequate support and design reforms.

The IMF acknowledges the Carbon Border Adjustment Mechanism (CBAM) as a legitimate tool to address carbon leakage and support global climate goals, but expresses serious concern that its design—relying on product- or country-specific carbon intensity estimates rather than actual emissions—risks distorting trade and disproportionately harming developing countries, especially those with limited capacity to implement domestic carbon pricing. It highlights that CBAM could erode export competitiveness for EMDEs like Mozambique and West African nations, imposing de facto high tariffs (e.g., up to 33% on cement), while noting that sub-Saharan Africa’s low emissions profile and institutional constraints make alternative, context-appropriate climate policies more suitable. The IMF stresses that CBAM’s fairness and effectiveness depend on international cooperation, technology transfer, and financial support to help developing countries build carbon pricing capacity.

2022

Views CBAMs as potentially useful climate incentives but warns they risk green protectionism and harm developing countries’ competitiveness without careful, equitable design and WTO-compliant implementation.

The IMF acknowledges that carbon border adjustment mechanisms (CBAMs) can serve as a climate tool by incentivizing countries to remain in or adopt carbon-pricing regimes, thereby supporting global mitigation efforts. However, it cautions that CBAMs raise serious concerns—including potential incompatibility with WTO rules, disproportionate negative impacts on developing countries’ export competitiveness due to higher embodied carbon in their industries, and limited effectiveness since they cover only traded emissions (typically <10% of total national emissions). The IMF stresses that CBAMs should not substitute for broader, more comprehensive carbon pricing and must be carefully designed—e.g., using country-specific emission benchmarks—to mitigate equity risks and avoid green protectionism.

2023

Views CBAMs as justified climate tools to curb leakage and protect competitiveness, but cautions against green protectionism and stresses fair design, WTO compliance, and support for developing countries.

The IMF acknowledges that carbon border adjustment mechanisms (CBAMs) serve a legitimate climate purpose by mitigating competitiveness concerns and reducing carbon leakage from unilateral carbon pricing, but emphasizes they must be carefully designed to avoid undermining trade fairness—particularly for developing countries—by ensuring rebates for exports, transparency, and compatibility with WTO rules. It notes the EU’s CBAM as a precedent while highlighting risks to export competitiveness of energy-intensive industries in emerging markets like India, Indonesia, and China under unilateral carbon taxes, and stresses that CBAMs should complement—not replace—cooperative climate finance and capacity-building support for developing economies.

AIIB (Asian Infrastructure Investment Bank)

AIIB (Asian Infrastructure Investment Bank) has not yet expressed a clear view on this question in our indexed reports.

UNIDO (UN Industrial Development Organization)

UNIDO (UN Industrial Development Organization) has not yet expressed a clear view on this question in our indexed reports.

ADB (Asian Development Bank)
2022

ADB views CBAM as a legitimate tool against carbon leakage but cautions it risks green protectionism and WTO non-compliance, especially for developing countries' export competitiveness.

The ADB acknowledges the European Union's Carbon Border Adjustment Mechanism (CBAM) as a tool designed to address carbon leakage and support climate mitigation efforts by extending the EU ETS to imports in energy-intensive sectors. However, it explicitly notes that CBAM is 'somewhat controversial' because it 'may be considered as “protectionism”' and raises questions about its compatibility with World Trade Organization rules. The ADB highlights concerns from developing countries regarding export competitiveness and the risk that such measures could disproportionately affect their industries—especially given that CBAM currently covers only direct emissions and excludes indirect emissions like those embedded in imported electricity. Thus, while recognizing CBAM’s environmental rationale, the ADB signals caution about its potential green protectionist effects and trade equity implications for developing economies.

2023

Cautiously critical: sees CBAM as potentially climate-effective but dangerously inequitable and protectionist unless redesigned with global coordination, revenue recycling, and support for developing economies.

The ADB acknowledges the CBAM’s stated climate objective—preventing carbon leakage—but expresses serious concern that its unilateral design risks undermining climate equity and exacerbating economic inequality between developed and developing economies. It highlights that the CBAM may disproportionately harm developing Asian economies with limited statistical capacity, weak carbon accounting infrastructure, and high dependence on EU exports of emissions-intensive goods, while also conflicting with the UNFCCC principle of 'common but differentiated responsibilities.' The ADB advocates for minimizing CBAM’s scope, ensuring WTO compatibility, recycling revenues to support developing countries’ green transitions, and prioritizing globally coordinated carbon pricing over unilateral border measures.

2024

Views CBAMs as potentially effective for climate mitigation but warns they risk green protectionism unless designed to protect developing countries' trade competitiveness and equity.

The ADB acknowledges that carbon border adjustment mechanisms (CBAMs) can serve as a climate tool to reduce global CO₂ emissions—especially when extended beyond the EU to other OECD and ADB regional members—potentially cutting emissions by up to 15% at €200/MT CO₂. However, it stresses that CBAMs pose significant risks to developing Asian economies’ export competitiveness and global value chain integration, with estimated export declines of 2.0–3.7% depending on carbon price and coverage. The ADB explicitly frames CBAMs as raising concerns over fairness and equity, particularly for GVC supplier and developing economies, and warns of a trade-off between climate ambition and trade openness. Thus, while not rejecting CBAMs outright, the ADB conditions their legitimacy on careful design that mitigates adverse impacts on developing countries’ trade and development.

EBRD (European Bank for Reconstruction and Development)
2022

Views CBAM as a climate tool with leakage-prevention aims, but warns of competitiveness risks for unprepared developing exporters and calls for supportive capacity-building.

The EBRD acknowledges the CBAM as a climate policy tool aimed at preventing carbon leakage and incentivising domestic carbon pricing in exporting countries, but highlights significant risks to developing and transition economies—especially those with high-carbon-intensity exports—due to limited awareness, low preparedness, and potential competitiveness losses. It stresses that CBAM’s effectiveness and fairness depend on supporting affected firms (particularly SMEs) with technical assistance, green management capacity-building, and policy alignment, while noting that its impact varies widely across countries based on their carbon intensity and existing climate policies. The Bank neither explicitly labels CBAM as 'green protectionism' nor endorses it uncritically, instead framing it as a consequential external regulatory shock requiring urgent, context-sensitive adaptation by EBRD-region economies.

BIS (Bank for International Settlements)

BIS (Bank for International Settlements) has not yet expressed a clear view on this question in our indexed reports.

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