This paper explores
how export rebates under the EU Emissions Trading System (EU ETS) can be
structured to avoid classification as export subsidies under WTO rules. While
the EU is phasing out free allowances and implementing a Carbon Border
Adjustment Mechanism (CBAM) to address import-bound carbon leakage, questions
remain about how to prevent export-bound carbon leakage and preserving the
competitiveness of the European industry without infringing subsidy
disciplines. The analysis shows that, if designed carefully, export rebates
would not qualify as ‘financial contribution’ within the meaning of the
Agreement on Subsidies and Countervailing Measures (ASCM) and thus would not
constitute subsidies at all, let alone prohibited ones.