“เกมพลังงาน” ผู้ประกอบการไทยต้องปรับตัวอย่างไร ภายใต้ CBAM และ EUDRHow Thai Enterprises Must Adapt to CBAM and EUDR in the Energy Game

The global trading landscape is undergoing a new set of rules, shifting from competition based on price and quality to competition based on 'carbon' and 'transparency', amid a significant global energy crisis that the world is conscientiously addressing. This situation demands that the industrial sector, particularly exporters, rapidly adapt to maintain their competitiveness on the world stage.

One crucial measure is the EU CBAM (EU Carbon Border Adjustment Mechanism) of the European Union, which is a mechanism for carbon pricing on imported goods, specifically for certain pilot product groups. At the same time, the EU Deforestation Regulation (EUDR) or Regulation (EU) 2023/1115 mandates that products entering the European market must not be linked to deforestation and must be traceable throughout the supply chain.

The CBAM is transforming 'energy costs' into 'carbon costs', particularly in the steel and aluminum industries, which have a total trade value exceeding 83.3 billion baht. Although Thailand has low carbon emissions in some cases, the stringent assessment criteria for carbon emissions from imported goods still place Thailand at a competitive disadvantage and at risk of losing market share.

One of the primary challenges is the cost of establishing the MRV (Measurement, Reporting, and Verification) system, access to certified auditors, and the risks associated with using Default Values, which may unnecessarily increase costs. Additionally, the United Kingdom is preparing to implement the UK CBAM, which has similar details, and the varying regulations between the European Union (EU) and the United Kingdom (UK) further burden the data compilation process, while the lack of recognized carbon pricing mechanisms in the country could lead to the risk of “double carbon payment”.

On the other hand, the EUDR is elevating 'data' to become a 'critical condition of trade', covering seven commodity groups: natural rubber, timber, palm oil, coffee, cocoa, soybeans, and cattle, including processed products listed in Annex I of the law, which must be able to prove they are not related to deforestation, are legally compliant, and can be traceably documented. Although Thailand is classified as low-risk, operators still need to prepare complete data, affecting all supply chain stakeholders, from farmers and raw material collectors to processing factories, manufacturers, exporters, and brand owners. However, being categorized as low-risk does not imply that Thai operators are exempt from the requirements of the EUDR, as they must still prepare data regarding the sources of raw materials, geolocation of production sites, traceability systems, and other relevant information comprehensively.

The challenges facing Thailand are not limited to compliance requirements but also include a production structure reliant on smallholder farmers, complex supply chains, and a data system that is not yet interconnected, particularly in the rubber industry, where linking data from plantations to factories remains a crucial issue that needs urgent development.

These measures can serve as a significant impetus for the Thai industrial sector to elevate from 'regulatory compliance' to 'competitiveness' through the development of data systems, traceability, and systematic supply chain management.

Under the changing rules of global trade, adapting to the CBAM and EUDR should not be seen merely as a burden, but as a 'strategic opportunity' to elevate businesses and create a long-term competitive advantage.
The Federation of Thai Industries (FTI) is committed to serving as a Partner for Competitiveness, connecting knowledge, technology, standards, and collaborative networks to support Thai enterprises in transforming 'Compliance' into 'Competitiveness' and achieving sustainable growth on the global stage.

In terms of policy, the Federation of Thai Industries recommends that the government accelerate action on five critical issues:
1. Develop domestic auditing capacity by urging the government to facilitate the accreditation of Thai auditing bodies in accordance with EU and UK standards, allowing operators, especially SMEs, to use actual data for assessment instead of Default Values, thus helping reduce hidden costs.

2. Accelerate carbon pricing mechanisms in the country, including carbon taxes and emissions trading systems (ETS), to preserve income and enhance competitive capability.

3. Establish support mechanisms for enterprises, such as One-Stop Service centers, low-interest loans, and Matching Funds, to help upgrade MRV systems - crucial mechanisms for measuring, reporting, and verifying greenhouse gas emissions data.

4. Develop a Decarbonization Roadmap, particularly in the steel and aluminum industries, to clearly and economically direct carbon reduction efforts.

5. Promote data system connectivity and Traceability between the public and private sectors, reducing the redundancy of data entry and assisting SMEs/smaller enterprises in accessing systems without incurring excessive cost burdens.

Additionally, the Agricultural Industry Institute has been transferring knowledge to enterprises on developing the FTI AgriTrace Platform and collaborating with the Office of Agricultural Research Development (or OARD) on the TH EUDR Traceability Platform, including certifying chain-of-custody standards for products (PEFC Chain of Custody) and sustainable forest management standards through the Thai Forestry Certification Office (TFCC).

At the enterprise level, readiness for the EUDR should be approached step by step, starting with assessing whether products fall under the regulations (Product Scope Assessment), analyzing the supply chain (Supplier Mapping), evaluating data gaps (Data Gap Assessment), developing traceability systems, and preparing data to support Due Diligence, beginning with systems that are appropriate for the business's scale without the need for substantial early-stage investment.

Ultimately, the CBAM and EUDR are not merely trade requirements but reflect that 'carbon' and 'data' are the new standards of competition. Enterprises that can adapt quickly, possess transparent systems, and ensure traceability will not only reduce risks but can also create opportunities and sustainable competitive advantages in the global market.