The European Commission has published guidance on CBAM certificates as importers begin preparing for the settlement of liabilities associated with goods imported during 2026. The first annual declaration and corresponding certificate surrender will be due by 30 September 2027.
The factsheet, published on 30 September, explains the role of certificates within the annual CBAM compliance cycle and distinguishes between the year in which goods enter the EU, the timing of certificate purchases and the subsequent reporting and settlement obligations.
Certificate sales through the common central platform are scheduled to begin in February 2027. The delayed start of certificate sales does not exclude goods imported during 2026 from the applicable CBAM charging regime.
Certificate prices follow EU carbon-market prices
The Commission has published certificate prices of EUR 75.36 for the first quarter of 2026 and EUR 75.28 for the second quarter.
The price for the third quarter was scheduled for publication on 5 October and was not available at the 4 October research cut-off.
For 2026, CBAM certificate prices are calculated using quarterly weighted averages of EU emissions allowance auction prices. From 2027, the methodology will change to weekly averages.
The certificate price alone does not determine the CBAM cost for a shipment. The number of certificates an importer must eventually surrender also depends on the embedded emissions of the goods and adjustments allowed under the applicable rules.
Product emissions determine the final liability
Physical shipment weight cannot therefore be used on its own to calculate CBAM costs. A steel consignment and a cement consignment with the same mass cannot simply be assigned the same certificate cost by multiplying their tonnage by the published certificate price.
The relevant liability estimate must incorporate the emissions associated with the imported goods as well as the applicable adjustments.
For finance teams, this creates a distinction between estimating the future CBAM liability and determining the eventual cash expenditure on certificates.
Import records and emissions data need to align
Companies preparing for the first settlement will need their import records, embedded-emissions calculations and certificate purchasing budgets to cover the same goods and reporting period.
The next certificate-price publication will provide an updated input for estimates covering third-quarter 2026 imports. It will not remove the requirement to reconcile the full year’s customs and emissions data before the 30 September 2027 reporting and surrender deadline.
