The European Commission’s proposed Regulation establishing a temporary decarbonisation fund does not adequately address export exposure to the competitive disadvantages created by CBAM and risks weakening the competitiveness of the European aluminium value chain. To effectively prevent carbon leakage, the fund requires substantial adjustments, including preserving ETS free allocation for exports and compensating for increased raw material costs linked to CBAM’s impact on the Aluminium European Premium Duty-Paid (EDP).