This Consultation Paper has not demonstrated that carbon leakage is a serious issue that is hindering achievement of Australia’s national commitments under the Paris Agreement that would necessitate additional measures beyond existing Government policy.
NFF do not support implementation of a CBAM as it resembles a non-tariff distorting market barrier and there remain unresolved questions as to its long-term durability and compliance with WTO rules. Carbon leakage is a global phenomenon that should be addressed in a collaborative manner between jurisdictions. As a matter of principle, Government should always strive to adopt policy with the least regulatory path of resistance. From this perspective, policy options that should be considered by Government to address leakage in the “ammonia and other derivates” commodity group should include financial assistance to offset costs of technology adoption and innovation support to uplift R&D and the development of clean, domestic fertiliser chemicals in Australia. Additional opportunities include the promotion of Australian fertilisers and agricultural commodities as low-carbon products and encouragement of trading partners to adopt similar standards as those in Australia.
Read the full submission here.