Amidst a challenging year for the climate, a recent Carbon Market Watch (CMW) report uncovered a concerning trend among the EU’s top 30 emitters, referred to as “Emissions Aristocracy”.
These companies span various sectors like power generation, steel, cement, oil refinement, and petrochemicals. And collectively, they contribute to 50% of the emissions accounted for by the EU Emissions Trading System (EU ETS).
Free Allowances Are Polluters’ “Freebies”
The EU ETS is a pivotal component of the European Union’s fight against climate change. Launched in 2005, it holds the distinction of being the world’s premier and most extensive transnational emissions trading initiative. Designed to curb greenhouse gas emissions, the system aligns with the EU’s overarching plan to fulfill climate objectives and global agreements like the Paris Agreement.
The CMW report, built upon existing research, sheds light on companies significantly polluting under the European carbon credit trading scheme. It identifies those not paying for their GHG emissions and sectors failing to meet their decarbonization commitments.
The European Commission (EC) had reported on the performance of the EU ETS for 2022 focusing on installations and sectors. But it didn’t reveal the entire story, according to CMW. Their new analysis promises a deeper understanding of emissions data, unveiling startling truths on free carbon allowances.
A policy expert at CMW and the report’s author, Lidia Tamellini, stressed the fact their analysis revealed:
“The EU ETS allows an Emissions Aristocracy to pollute without footing the bill. This report spotlights how these already hugely profitable companies are granted freebies. Rather than the polluter paying, it is the planet and society left carrying the tab.”
Under the EU ETS, the companies in the Emissions Aristocracy, despite generating substantial revenue, benefit from ‘free allowances’. That means they’re avoiding payment for the environmental harm caused by their planet-warming emissions.
The EU ETS is a market-driven climate policy, geared toward heavy industry and the power sector, that follows the ‘polluter pays principle’. It means emitters must pay for the environmental and social costs of their GHG emissions.
The Lion’s Share of EU Emissions is From Top 1%
CMW’s investigation found that while the power sector is responsible for most of the emissions, it pays for its pollution. However, companies in other sectors like steel, cement, and petrochemicals are among the top 30 polluters that receive huge amounts of free pollution permits.
The identified businesses are dominant players in their respective sectors.
The EU ETS is dominated by a small fraction of companies. In particular, the top 30 emitters alone account for over 50% of the scheme’s emissions in 2022, despite comprising less than 1% of total covered companies: 3,515. This highlights the huge responsibility of those companies in driving the climate crisis, underscoring greater accountability in their climate actions.

Given the total amount of EU emissions in 2022 and that covered by the ETS, only 30 businesses are accountable for generating about 25% of the total EU carbon footprint for last year.
However, within the EU carbon trading mechanism, major contributing sectors face minimal pressure for swift emission reductions, the report said. More remarkably, these sectors received about €47.6 billion in free allowances in 2022, essentially granting them a free-to-pollute pass.

As can be seen in the chart, giving out free allowances especially favored the heavy industries. Prior to 2016, some sectors received more allowances than their carbon emissions. For the last 3 years (2020 – 2022), free allocation covered industrial emissions by 104%, 89%, and 95%, respectively.
The redirection of auctioning revenues toward climate-related purposes under the recent EU ETS revision signifies a loss in vital funding for innovative technologies, support to vulnerable households and small businesses, and climate mitigation efforts.
A handful of prominent companies are featured in the report’s list. RWE, a multinational energy corporation, holds the title as the largest emitter in the EU. Additionally, heavy industry entities like ArcelorMittal, ThyssenKrupp, and HeidelbergCement secure their presence within the top 10 of the listed emitters.
The report delves into the continued use of free allowances within specific sectors, hindering the European economy’s path to decarbonization. The analysis also highlights how the free allocation system has failed in fostering an efficient decarbonization path for heavy industry.
Make the Emissions Aristocrats Pay
The European Commission is in the process of formulating its post-2030 climate framework. Addressing how polluters evade paying the complete cost of their emissions should be a top priority of the EU ETS.
Carbon Market Watch advocates for a more robust EU ETS aligned with achieving climate neutrality by 2040. This entails phasing out free allowances for heavy industries and promptly implementing an auctioning system ahead of the current plan, which extends free allocation until 2034.
The EC must establish stricter regulations for major emitters to ensure genuine accountability and responsibility for polluting. For Tamellini, “Closing the loopholes in the EU ETS is essential…the Emissions Aristocracy has had it easy for too long.”
Carbon Market Watch report sheds light on the stark reality of the EU’s emissions landscape. Going beyond the surface, their analysis pinpoints key companies, sectors, and emission trends within the EU ETS, highlighting the urgent need for accountability and stronger decarbonization strategies.
The post Top 1% of Polluting Companies Cause 50% of EU ETS Emissions appeared first on Carbon Credits.
Carbon Footprint
Want a simpler way to buy carbon credits? Discover our carbon marketplace
Most businesses that decide to act on their net-zero targets reach the same point of friction. Buying carbon credits has meant tracking down brokers, sitting through sales calls, and requesting a quote just to learn a price, sometimes with limited proof of what you are buying.
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Carbon Footprint
Climate-Linked Supply Chain Risk Is Already in Your P&L
The earnings calls that quietly reframed climate from sustainability question to operating risk.
Three earnings calls in the last 18 months tell the story without any help from a press release.
Hershey, May 2024: cocoa price exposure compresses margin, and the company attributes part of the cost shock to West African weather. Olam, July 2024: coffee climate exposure quantified in the annual report. JBS, January 2025: supply chain climate disclosures expanded materially in response to investor pressure and regulatory expectation. None of these companies issued the announcement as climate news. They issued it as financial news. The climate-linked supply chain risk did not arrive with a sustainability framing; it arrived as a P&L line.
You are probably reading this article because you suspect the same thing is happening to your business. This piece walks through what is showing up on which earnings calls, how procurement and finance leaders are quantifying the exposure, and what serious corporates are doing about it before the regulator asks.
Where climate risk has already appeared in earnings
The pattern is consistent across resource-intensive sectors. A weather event compresses supply, the price spikes, the cost flows through the income statement, and the analyst on the call asks whether the event is anomalous or structural. Increasingly, the honest answer is the second one.
Cocoa is the cleanest example. The 2023 to 2024 West African harvest fell sharply on the back of erratic rainfall and disease. Cocoa futures more than tripled. Companies with concentrated West African sourcing absorbed the cost; companies with diversified sourcing absorbed less. The exposure was not climate as ESG topic. It was climate as cost of goods.
Coffee follows the same pattern. Brazilian and Vietnamese harvests have moved on weather more sharply across the last several seasons. Roasters with long-tenor supplier relationships and origin diversification have managed the volatility; roasters with spot-market exposure have not. Wheat, sugar, palm oil, beef: the same dynamic in different commodities, a pattern the IPCC AR6 Working Group II report projects will intensify across agricultural systems through mid-century.
What this means: climate risk is no longer a footnote in the 10-K. It is a line item the CFO has to explain on the call.
The three commodity exposures that hit margin first
For most companies with material Scope 3 exposure, three exposures dominate the near-term P&L risk.
- Concentrated single-origin sourcing in a climate-vulnerable region. If your tier-one supply for any material commodity sits in one geography, you have a concentration risk that climate amplifies. Diversification across origins is the obvious hedge, but it takes years to build and requires relationships you cannot acquire by tender.
- Supplier financial fragility under climate stress. Smallholder farmers, who supply a large share of the global cocoa, coffee, and palm oil market, do not carry the balance sheets to absorb yield shocks. When yields collapse, they exit. When they exit, your supply base shrinks, and the surviving suppliers raise prices. The risk is structural, not cyclical.
- Logistics and storage exposure to extreme weather. Hurricane disruptions to Gulf shipping, drought-driven Panama Canal restrictions, flooding in European inland waterways: each of these has moved input costs in the last three years, a pattern documented in Munich Re’s natural catastrophe data. The exposure shows up as a one-quarter event in the financial press but accumulates over time on the cost line.
TCFD and ISSB disclosure changes
The disclosure architecture has now caught up with the risk. The Task Force on Climate-related Financial Disclosures, whose recommendations are now embedded in the ISSB’s IFRS S2 climate standard, requires companies to disclose climate-related risks across physical and transition categories, with quantification where possible.
For physical risk specifically (the climate-linked supply chain risk you are reading about), the disclosure must address both acute exposures (extreme weather events) and chronic exposures (gradual changes in temperature, precipitation, and growing seasons). The disclosure must address the time horizon over which the risk is material, the parts of the value chain exposed, and the financial impact under different scenarios.
The CSRD imposes similar requirements under European law, with double materiality (both financial and impact materiality) embedded in the assessment. The practical effect: your auditors and your investor relations team now need a defensible answer to the climate-linked supply chain risk question, and the answer needs to be quantified.
What procurement and finance can do now
Three actions matter near-term.
Map your exposure. Most companies do not have a clear view of which tier-one and tier-two suppliers sit in which climate-vulnerable geographies. Without the map, you cannot quantify the risk, and without the quantification, you cannot disclose it credibly. The map is the foundation, and World Resources Institute climate risk research provides useful public tooling to start.
Diversify and deepen, in that order. Diversification across origins reduces concentration risk, but the deeper move is to invest in the resilience of the suppliers you already have. Regenerative practices, agroforestry, soil health interventions: these reduce yield volatility under climate stress and protect your input cost trajectory.
Embed the climate spend inside procurement, not outside it. Treating climate risk as a sustainability cost line subordinates it to the ESG budget. Treating it as a procurement and resilience investment puts it in the budget that matters, which is the cost-of-goods budget that the CFO defends quarterly.
Nature-based supply chain investments are the asset class designed for exactly this purpose. They sit inside the value chain, they reduce climate-linked supply risk, they generate verifiable Scope 3 reductions, and they produce the documentation an auditor and a regulator can both test.
If you are quantifying climate-linked supply chain risk in advance of the next earnings cycle or the next disclosure period, the carbon and sustainability experts at Carbon Credit Capital can help you map your exposure and structure a Dual-Value Model response that addresses reduction, resilience, and disclosure-readiness in a single program. Schedule a consultation.
Carbon Footprint
Where should an SME start with a carbon action plan?
More and more small and medium-sized businesses are hearing the same question from their larger customers: What is your carbon footprint? That question now travels down entire supply chains, and it arrives next to tender requirements, certification criteria, and rising customer expectations.
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