European Association
of Sugar Manufacturers

European Association
of Sugar Manufacturers

Published On: May 13th, 2025

CEFS position on Carbon Border Adjustment Mechanism (CBAM)

Carbon Border Adjustment Mechanism (CBAM)

Achieving carbon neutrality by 2050 is the EU Green Deal’s core objective. However, in a globalised economy without common greenhouse gas (GHG) reduction standards, differences in ambition levels are inevitable. This creates a risk of carbon leakage, where production shifts from the EU to countries with lower environmental standards.

The EU Emissions Trading System (EU ETS) has so far mitigated this risk by providing free emission allowances to sectors exposed to international competition, including the sugar sector. Although free allowances will steadily fall for all sectors over the coming years, for sectors covered by the CBAM this process is significantly accelerated.

The accelerated phase-out of free allowances under CBAM will significantly increase production costs for EU sugar manufacturers without ensuring equivalent protection against imports of sugar from third countries. The EU sugar sector sees this as a major threat to its competitiveness, the more so given that third country cane sugar manufacturers benefit from the full use of bagasse (the fibrous residue remaining after sugar has been extracted from sugar cane) as a renewable energy feedstock.

LOSS OF FREE ALLOWANCES: A COMPETITIVE DISADVANTAGE FOR EU SUGAR MANUFACTURERS

EU sugar production is highly energy- and trade-intensive, making it particularly vulnerable to carbon leakage. Despite efforts to reduce its carbon footprint, the significant investment is still needed to complete the transition away from fossil fuels. The removal of free allowances will:

  • Increase production costs for EU sugar manufacturers while competitors in third countries face no similar carbon pricing.
  • Jeopardise future investments in decarbonisation, as companies will be burdened with rising costs instead of reinvesting in green technologies.
  • Distort competition, as imports from non-EU countries will remain largely unaffected, leading to an uneven playing field.

Phasing out free allowances without effective compensation mechanisms undermines the industry’s ability to sustain this advantage.

CBAM FAILS TO ADDRESS CARBON LEAKAGE IN THE EU SUGAR SECTOR

While CBAM is intended to prevent carbon leakage, it is not a viable alternative to free allowances for the sugar sector. Its fundamental flaws include:

  • Inappropriate methodology: CBAM is designed for direct emissions but does not account for the full life-cycle carbon footprint of agricultural products like sugar.
  • Failure to prevent deforestation: The current CBAM framework does not properly account for land-use changes and deforestation-related emissions, making it ineffective in addressing the broader environmental impact of sugar imports.
  • Greenwashing risk: Just as seen with biofuels, the exporters of sugar to the EU are likely to engage in “resource shuffling”, sending their greenest production to the EU and saving the rest for less-regulated markets. This will do nothing to reduce overall global emissions.
  • Narrow focus on carbon emissions: CBAM ignores other key sustainability factors, such as biodiversity loss, labour conditions, and water use, which are essential for fair product comparisons.

CEFS CALLS FOR A FAIR AND EFFECTIVE CLIMATE POLICY

As the European Commission reviews the CBAM this year, CEFS urges the European Commission to recommend maintaining the exclusion of the sugar sector from the policy.

The European Commission must adopt a cautionary approach. This means:

  • Not extending CBAM’s product scope as long as the impact assessment planned by the European Commission has not been carried out and validated by the Member States; extending CBAM’s product scope only to sectors expressing a need for protection through this mechanism
  • Supporting the transition away from fossil fuels by providing funding for low-carbon investments and compensating higher production costs, including via the Competitiveness Fund, Clean Industrial State aid Framework and the Industrial Decarbonisation Accelerator Act.
  • Creating a market environment that reflects Green Deal ambitions while preventing unfair competition from countries with lower sustainability standards.
  • Ensuring a level playing field by pricing fossil carbon used in chemical production, supporting bio-based alternatives, and promoting a truly sustainable sugar sector.
Eliminating free allowances without an effective carbon leakage protection mechanism threatens the future of EU sugar manufacturing. If the EU is serious about its climate ambitions, it must adopt policies that support industries striving for sustainability – rather than penalising them.

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Frequently asked questions

Does eating too much sugar make children hyperactive?2018-02-15T10:31:22+00:00

Scientific studies to date have confirmed no causal relationship between sugar consumption and attention deficit/hyperactivity disorder. In general, it was found that sugar does not affect the behaviour or cognitive performance of children. In terms of risk factors/causes, the U.S. Centers for Disease Control and Prevention indicates that current research shows that genetics plays an important role.

Can people with diabetes eat sugar?2018-02-15T10:29:02+00:00

Dietary advice for people with diabetes has changed over the last few decades. The latest scientific advice from the European Association for the Study of Diabetes guidelines for diabetes support a moderate intake of ‘free sugars’ as part of a healthy balanced diet by stating that if desired and if blood glucose levels are satisfactory, moderate intakes of free sugars (up to 50 g/day) may be incorporated within the diet of individuals with Type-1 and Type-2 diabetesT1.. Achieving and maintaining a healthy body weight through diet and physical activity is most important for people with diabetes. For individual dietary advice, people should consult their healthcare professional.

Does sugar cause diabetes?2018-02-15T10:28:11+00:00

Sugar has not been established as a cause of diabetes. Obesity and lack of physical activity are reported to be the major risk factors of Type-2 diabetes.

Type-2 diabetes is characterized either by an inadequate production of the hormone insulin or an inability of the body to utilize the insulin that is available. The body needs insulin to keep blood glucose levels within a narrow range. In most people, when food is consumed, blood glucose levels rise and the body produces insulin to bring them back down. In people with diabetes, this insulin response is defective and, if not treated, blood glucose levels can become dangerously high.

What causes tooth decay? How can it be prevented?2018-02-15T10:26:49+00:00

Frequent consumption of foods containing fermentable carbohydrates (such as sugars or starch) may increase the risk of tooth decay, especially in those who do not brush their teeth twice a day with fluoride toothpaste. Fermentable carbohydrates are, for instance, part of bread, cereals, biscuits, sweets or fruits.

CEFS supports the Eurodiet recommendation to limit the number of sugary eating or drinking occasions to 4 per day.

The best way to prevent tooth decay is to follow the advice from the World Dental Federation to brush teeth twice a day with fluoride toothpaste.

Is there less energy in foods that are labelled as reduced in sugars?2023-03-12T10:32:56+00:00

Replacing sugars in food does not necessarily lead to an energy reduction. As previously mentioned, sugar has many properties in addition to sweetness; it contributes to the colour, texture and flavour in foods. If sugar is reduced or replaced in carbohydrate based products (e.g., breakfast cereals or biscuits) starch typically substitutes for sugar but does not deliver any reduction in calories. In other products, where sugar is replaced with other ingredients, this may result in little or no calorie reduction in the reformulated product. Moreover, a recent consumers’ survey shows that consumers usually expect foods with a ‘reduced sugars’ claim to be also reduced in energy.

Are soft drinks particularly fattening?2018-02-15T10:25:46+00:00

The question of whether there is a difference between the way the body processes calories from liquid products and those in solid foods is an evolving area of research. The U.S. report on Dietary Guidelines (2010) reported “limited body of evidence shows conflicting results about whether liquid and solid foods differ in their effects on energy intake and body weight”.  The most important is the balance of energy intake and energy expenditure.

Examples of energy content of some beverages:[1]

  Total sugars (range – g/100 ml) Fat (average value – g/100 ml) Energy (average value – kcal/100 ml)
100% orange juice 8.4-11.4 Trace 42.4
100% grape juice 15-16.5 Trace 67.5
 Sugar-sweetened soda 9.1-11.2 Trace 44.1
100% apple juice 9.8-11.5 Trace 46.8
Whole milk 4.6 3.6 65.1
Semi-skimmed milk 4.6 1.6 48.1

 

[1] Agence nationale de sécurité sanitaire de l’alimentation, de l’environnement et du travail (Anses). Tables de composition nutritionnelle Ciqual 2008.

Will eating sugar make me fat?2023-03-16T20:44:23+00:00

Obesity is caused by an imbalance between energy expenditure and energy consumed from all types of food and drinks. Thus, as with all foods, it just depends on the quantity eaten. Whatever their source – protein, carbohydrate, including sugar, or fat – once eaten, the body stores any surplus calories.

  • A man who has a moderately active lifestyle needs approximately 2,500 kcal/10,500 kJ per day.

  • A woman who has a moderately active lifestyle needs approximately 2,000 kcal/8,400 kJ per day.

A number of parameters play a role in the imbalance between energy intake and energy expenditure

Does sugar cause coronary heart disease?2018-02-15T10:16:09+00:00

A number of factors are associated with an increased risk of developing coronary heart disease (CHD) – the main ones are smoking, high blood pressure, high blood cholesterol, and obesity. Current scientific evidence does not support a link between sugar consumption and cardiovascular diseases. The key dietary component in prevention of CHD is dietary fat, particularly saturated fat intake.

Is sugar addictive?2018-02-15T10:15:19+00:00

Scientific studies in humans do not support the hypothesis that sugar may be physically addictive or that addiction to sugar plays a role in eating disorders. Recently, NeuroFAST, an EU-funded project aiming at investigating the common neurobiology involved in eating behaviour, addiction and stress indicated that the current evidence does not allow concluding that a single food substance can account for the fact that people overeat and develop obesity. In humans, there is no evidence that a specific food, food ingredient or food additive causes a substance-based type of addiction.

Does eating sugar cause a fluctuation in blood sugar levels?2018-02-28T15:50:32+00:00

For healthy people, fluctuations in blood sugar levels are not an issue. Eating sugar causes a smaller rise in blood glucose level than eating starchy foods like white bread, white rice or mashed potatoes. Sugar is therefore rated as medium glycaemic index (GI). When sugar is added to some foods, such as breakfast cereals, it can actually lower the GI of the final product.

What is the glycaemic index?

The ‘glycaemic index’ (GI) has been introduced to rank carbohydrates according to their ability to raise blood glucose levels. Glucose is the typical standard against which the GI of other foods is measured and has a GI of 100 (reference glucose). Fructose, on the other hand, has a low GI (≈15) and sucrose an intermediate GI (≈65), i.e. lower than for instance white bread (≈75).

Does sugar provide empty calories?2023-03-12T11:06:02+00:00

Sugar is a nutrient and provides 4 kcal / 17 kJ of energy per gram. However, sugar is rarely eaten on its own. As in addition to its sweet taste, sugar contributes to the colour, flavour and texture of food, adding sugar to foods can improve their taste and palatability, thereby increasing the range of foods that people can eat.

Research does not suggest that a higher consumption of sugars necessarily leads to a lower intake of micronutrients (vitamins and minerals). Total energy intake as well as the overall balance of the diet is the main predictor of micronutrient intake.

Is brown sugar healthier than white sugar?2018-02-15T10:06:41+00:00

No. The term ‘brown’ sugar covers a broad range of products including raw (i.e. partially refined) and white sugar blended with caramelised or other brown-coloured food ingredients (e.g. molasses). They deliver colour and flavour to products and contain the same amount of calories. Brown sugars add variety and choice in ingredients.

Is unrefined sugar healthier than refined sugar?2018-02-15T10:06:06+00:00

No. Both have the same energy content and are treated the same way by the body. In fact, all crystallised sugar has been refined to some degree. So-called ‘unrefined’ sugar has only been partially refined to retain colour and flavour.

What is the role of sugar in a healthy and balanced diet?2018-02-15T10:05:07+00:00

A healthy balanced diet is one that has a variety of foods in moderation. The EU’s independent scientific advisory body (EFSA) recommends that 45-60% of our daily energy intake come from carbohydrates (including starches and sugars). Carbohydrates are the most important fuel for our brains and provide our bodies with the energy our organs need to function.

Our daily energy intake should be made up of:

  • 45-60% carbohydrate
  • 20-35% fat
  • 10-15% protein
Has the consumption of sugar increased over the years?2018-02-15T10:04:00+00:00

There is a common misperception that sugar consumption has risen over the years. However, the sugar supply in the EU has remained stable for over 40 years and has, on average, amounted to about 33 kg per capita per year between 1970 and 2011, as demonstrated by the agricultural statistics provided by the FAO. These figures account for the sugar supply meaning the apparent consumption, and therefore, the actual amounts consumed are lower.

What role does sugar play in food?2023-03-12T11:08:05+00:00

Sugar is first and foremost used because of its sweetening properties. It has a clean sweet taste with no aftertaste and is the reference against which other sweeteners are compared. Beyond its sweetening properties, sugar provides structure and texture to many traditional foods, such as bakery products and jam. Sugar helps to create crispness and texture in biscuits, and is central to the browning process that gives bread and pastries their traditional golden colour and characteristic flavour.

In some products, sugar can act as a natural preservative. Reducing sugar concentration in a food product may shorten its shelf life and impact on quality. For example, a jam with reduced sugars content will need to be stored in the fridge.

No single ingredient can replace sugar in all foods and replicate its many functions at the same time. Thus, replacing sugar often results in the use of several additional ingredients and additives, which may result in higher calorie content.

 

How can I spot sugar on labels?2021-07-05T14:39:37+00:00

What are the different types of sugar and where are they found?2021-02-03T18:46:16+00:00

There are many different types of sugars. They all provide 4 kcal/17 kJ per gram. The sugars most commonly present in foods include: sucrose, glucose, fructose, maltose and lactose. All of these sugars occur naturally.

  • Sucrose is simply table sugar.
  • Glucose, fructose and sucrose are found in honey, and fruit and vegetables (see table below).
  • Maltose is a sugar produced by starch breakdown and is found in germinating cereals such as barley
  • Lactose is found in milk and milk products

Examples of sources of sugars in various fruits, vegetable and honey:[1]

How much energy is there in sugar?2021-02-17T09:48:26+00:00

Just like other carbohydrates, such as starch, sugar provides 4 kilocalories (kcal) or 17 kilojoule (kJ) of energy per gram. This is the same as proteins, but it is lower than fat and alcohol:

What is sugar?2018-02-19T12:24:14+00:00

Sugar is a carbohydrate. Carbohydrates are the most important fuel for our brains and provide our bodies with the energy our organs need to function.

Sugars are present in nature; plants make sugars through photosynthesis. The sugar (sucrose) you find in your sugar bowl is simply water-extracted from beet or cane by sugar producers. Sucrose found in a fruit and sucrose used to bake a cake are identical. All have the same calorific values (4 kcal/ 17 kJ of energy per gram). The body does not distinguish between sugars used in manufactured food and drinks or in the home, and those found naturally in foods.

To function correctly, our body needs:

CEFS is an international non-profit organisation, representing sugar manufacturers from the EU and Switzerland. 

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