The VIK supports the discussion of the EU Commission to incorporate an improved emission trading scheme. In this regard, the VIK also generally welcomes all EU initiatives to improve carbon leakage protection for the European industry. The following aspects, however, should be taken into accounti. Before the outstanding issues and concerns listed below such as WTO compatibility, carbon footprint assessment, certification and verification system, risk of protectionism escalation, export refunds, etc. have been resolved, a CBAM system should not be introduced.