European aluminium importers must account for carbon liabilities arising from 2026 imports even though the associated CBAM certificates will not be purchased and surrendered until 2027, under the European Commission’s guidance on the definitive Carbon Border Adjustment Mechanism.
The first annual CBAM declaration and corresponding certificate surrender are due by 30 September 2027 and will cover imports made during 2026. Sales of CBAM certificates through the common central platform are scheduled to start in February 2027.
This timetable separates the period in which the aluminium imports generate the CBAM liability from the later period in which importers procure and surrender the certificates required to settle it.
Quarterly pricing applies to 2026 imports
The certificate-price mechanism also changes between the two years. For 2026 imports, CBAM certificate prices are based on quarterly averages of EU emissions allowance auction prices.
The European Commission has published prices of EUR 75.36/tCO₂ for the first quarter of 2026 and EUR 75.28/tCO₂ for the second quarter. From 2027, the pricing methodology moves to weekly averages.
The published carbon prices do not represent a fixed surcharge applied directly to every tonne of aluminium imported into the EU. Importers first have to establish the applicable certificate requirement using the relevant embedded-emissions data and CBAM adjustment rules, after which the resulting certificate position can be converted into a monetary exposure.
Contract pricing and statutory liabilities remain separate
The timing between aluminium shipments and certificate settlement creates a separate commercial issue for contracts negotiated before the final CBAM liability is known.
Suppliers may seek to recover carbon-related costs through the aluminium price or a dedicated contractual provision. However, a negotiated surcharge does not automatically correspond to the importer’s eventual statutory CBAM liability.
For financial planning, companies can separately track import volumes, emissions assumptions and certificate-price assumptions. Keeping those variables distinct allows individual changes in the exposure to be identified as underlying shipment, emissions or carbon-price assumptions are revised.
Combining all three elements into a single fixed carbon premium could obscure which component has changed and make subsequent adjustments more difficult.
The 2027 settlement timetable provides importers with additional time to arrange the financing required for their 2026 CBAM liabilities. It does not remove the carbon cost associated with aluminium imported into the EU during 2026.
