Background
CBAM is part of the EU’s ‚Fit for 55‘ package and requires companies importing emission-intensive goods into the EU to purchase CBAM certificates in order to cover the difference between the carbon price paid in the country of origin and the price of allowances under the EU Emissions Trading System 1 (EU ETS 1). A CBAM certificate is the unit that authorised CBAM declarants must purchase and surrender in order to fulfil their financial obligations under the CBAM Regulation. Each CBAM certificate represents one tonne of CO2-equivalent emissions embedded in the imported goods (embedded emissions). If a carbon price has already been paid for the embedded emissions in a third country, the number of CBAM certificates to be surrendered can be reduced under certain circumstances in order to prevent a double burden.
In addition to the CBAM Regulation (Regulation (EU) 2023/956), the relevant provisions of the CBAM Certificate Price Implementing Regulation (Commission Implementing Regulation (EU) 2025/2548 of 10 December 2025 laying down the rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council with regard to the calculation and publication of the price of CBAM certificates) form the relevant legal framework. The delegated regulation pursuant to Article 20(6) of the CBAM Regulation, which will specify the timing, administration, structure and level of fees as well as other aspects related to the management of the sale and repurchase of CBAM certificates, has not yet been adopted. The same applies to the specific modalities of offsetting carbon prices paid in third countries, in accordance with Article 9(5) of the CBAM Regulation.
Sale of CBAM certificates and important dates
The sale of CBAM certificates to authorised CBAM declarants will start in February 2027. From 2027 onwards, an authorised CBAM declarant must ensure that, at the end of each quarter, the number of CBAM certificates held on their account in the CBAM Registry is equal to at least 50% of embedded emissions of all goods they have imported since the beginning of the calendar year. Pursuant to Article 22 (2) of the CBAM Regulation, this rule is calculated on a quarterly basis, which means that authorised CBAM declarants must ensure that they meet this requirement at the end of each quarter of each calendar year (31 March, 30 June, 30 September and 31 December). The obligation to surrender CBAM certificates in the CBAM Registry will start retrospectively in 2027 for the imports or emissions in 2026, that means authorised CBAM declarants must acquire CBAM certificates retrospectively in 2027 in view of their embedded emissions in 2026 and surrender them in the CBAM Registry by 30 September.
Important dates in 2027
| Date | Explanation |
|---|---|
| 01/02/2027 | Start of the sale of CBAM certificates to authorised CBAM declarants for embedded emissions of imports in 2026 and 2027. |
| 31/03/2027 | Holding a number of CBAM certificates on the CBAM account that corresponds to at least 50 per cent of the embedded emissions of CBAM goods imported since the beginning of 2027. |
| 30/06/2027 | Holding a number of CBAM certificates on the CBAM account that corresponds to at least 50 per cent of the embedded emissions of CBAM goods imported since the beginning of 2027. |
| 30/09/2027 | Surrender of CBAM certificates for the embedded emissions of 2026 specified in the CBAM declaration. Holding a number of CBAM certificates on the CBAM account that corresponds to at least 50 per cent of the embedded emissions of CBAM goods imported since the beginning of 2027. |
| 31/10/2027 | Possibility of requesting the repurchase of any surplus CBAM certificates purchased for embedded emissions in 2026. |
Calculation and publication of CBAM certificate prices
The Commission calculates the price for CBAM allowances based on an average of the auction prices for (EUA) EU ETS 1 allowances, which are auctioned on the auction platforms on a regular basis throughout the year. This price is calculated in euros and publicly announced by the Commission. Accordingly, the cost of compliance under CBAM may rise or fall in line with trends in the European carbon market.
The Commission will use an average quarterly price as the basis for determining the price for CBAM allowances for the embedded emissions in 2026. Accordingly, CBAM declarants must purchase a corresponding number of CBAM allowances for the embedded emissions in the four quarters of 2026 at the price applicable for the actual quarter.
From 2027 onwards, the Commission will calculate and publish the price of CBAM allowances on the basis of the auction prices‘ weekly average under EU ETS 1. The above-mentioned obligation for CBAM declarants to hold CBAM allowances in the CBAM Registry at the end of each quarter corresponding to at least 50 per cent of the embedded emissions of all goods imported by the CBAM declarant since the beginning of the calendar year will then apply.
In particular, the CBAM Certificate Price Implementation Regulation lays down the following procedure for the calculation and publication of prices of CBAM certificates:
The Commission calculates the price for CBAM certificates based on an average of the auction prices for (EU) EU ETS 1 allowances, which are auctioned on the auction platforms on a regular basis throughout the year. This price is calculated in euros and publicly announced by the Commission. Accordingly, the cost of compliance under CBAM may rise or fall in line with trends in the European carbon market.
The Commission will use an average quarterly price as the basis for determining the price for CBAM certificates for the embedded emissions in 2026. Accordingly, authorised CBAM declarants must purchase a corresponding number of CBAM certificates for the embedded emissions in the four quarters of 2026 at the price applicable for the actual quarter.
From 2027 onwards, the Commission will calculate and publish the price of CBAM certificates on the basis of the weekly average of auction prices under EU ETS 1. The above-mentioned obligation for authorised CBAM declarants to hold CBAM certificates in the CBAM Registry at the end of each quarter corresponding to at least 50% of the embedded emissions of all goods imported by the authorised CBAM declarant since the beginning of the calendar year will then apply.
In particular, the CBAM Certificate Price Implementation Regulation lays down the following procedure for the calculation and publication of prices of CBAM certificates:
The European Commission determines the price of CBAM certificates for each quarter of 2026 after the end of the respective quarter and publishes them on its website in the second week following the end of the quarter.
| Quarter of application | Date of publication | Price (EUR) |
|---|---|---|
| Source: EU-Kommission (2026) | ||
| Q1 2026 | 07/04/2026 | 75.36 |
| Q2 2026 | 06/07/2026 | 75.28 |
| Q3 2026 | 05/10/2026 | 82.32 |
| Q4 2026 | 04/01/2027 | |
For 2027, the Commission will determine the price of CBAM certificates on a weekly basis based on the auction prices under EU ETS 1 from the previous week. On the first (working) day of the following week the prices will be published on the Commission's Website. In addition, the applicable CBAM certificate price for the purchase will be displayed in the CBAM Registry. The ‘new’ CBAM certificate price for each week will become valid one day after the CBAM certificate price is published on the Commission's Website and will therefore only be transferred to the CBAM Registry on the day following the website publication. This also means that the price for CBAM certificates of one week is still valid for the purchase of CBAM certificates on the first working day of the following week. The ‘newly’ determined price of a specific week is valid from the second working day of that week
Organisation and management of purchasing and repurchasing
Authorised CBAM declarants shall purchase CBAM certificates and request the repurchase via the CBAM Registry (CBAM portal for declarants). This is the same portal used to submit the authorisation application and declarations. Purchases (and repurchases) will be financially processed via the common central platform (CCP), which will be linked to the CBAM registry and which will be designated by the Commission as part of a joint procurement procedure between the Member States and the European Commission. Further information will be provided once the CCP has been designated. Only authorised CBAM declarants may purchase CBAM certificates. In addition, unlike emission allowances in the EU ETS 1, CBAM certificates are non-tradable and non-transferable. They can only be used by those authorised CBAM declarants who have purchased them.
Further informationen
Calculation of the number of certificates required
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