Electricity importers entering the EU’s CBAM certificate market in 2027 will need to manage two distinct carbon-cost exposures: the settlement of 2026 imports and the pricing of electricity imported during 2027.
The two years use different certificate-pricing mechanisms. For 2026 imports, prices are calculated from quarterly weighted averages of EU emissions allowance auction prices, while certificates associated with 2027 imports will use weekly averages.
The European Commission has published a certificate price of EUR 75.36/t for the first quarter of 2026 and EUR 75.28/t for the second quarter. The applicable import quarter determines the price basis for the 2026 liability.
2027 certificate sales begin in February
CBAM certificate sales are scheduled to start on February 1, 2027. Importers will have until September 30, 2027 to submit their first annual declaration and surrender the required certificates.
The opening of the certificate sales platform does not change the pricing basis for electricity imported in 2026. Those liabilities remain linked to the relevant quarterly pricing periods rather than becoming subject to the weekly price applicable to 2027 imports.
Importers will consequently have to finance the previous year’s CBAM liability while simultaneously managing carbon-price exposure on new electricity business under the weekly pricing framework.
Procurement choices depend on liquidity and cost certainty
In an August analysis, consultancy Carboneer assessed rule-based approaches to certificate procurement against liquidity requirements, cost certainty and operational effort.
Its illustrative comparison used 2024 historical prices. The exercise was not evidence of realised savings and did not establish that any particular procurement strategy would consistently outperform alternatives.
For electricity traders, the distinction between liability calculation and procurement is important. The amount owed must first be established using the applicable emissions quantity and eligible deductions. The timing of certificate purchases cannot correct an incorrect emissions calculation or compensate for an unsupported deduction for carbon costs paid abroad.
2026 and 2027 require separate margin assumptions
Separating the two exposures can also affect how power traders calculate margins.
The 2026 import book requires provisions consistent with the relevant quarterly price periods, while transactions involving 2027 imports require assumptions reflecting the weekly certificate-price mechanism.
The delay between electricity imports and the eventual cash settlement gives companies additional time to organise procurement and financing. It does not eliminate the carbon cost embedded in the economics of electricity that has already entered the EU market.
