In the European Union, authorised importers remain legally responsible for CBAM declarations and certificate surrender, while the economic burden can move through industrial supply chains. The European Commission set the third-quarter 2026 certificate price at €82.32 per tonne of carbon dioxide equivalent, one component of the calculation rather than a universal surcharge on steel or aluminium.
The EU imported €111.23 billion worth of products under existing CBAM codes in 2025. That customs value indicates potential commercial exposure, but it does not establish who will surrender certificates, how much will be payable or whether buyers can pass costs to downstream customers. The authorised CBAM declarant is responsible for the relevant declaration and surrender, subject to applicable legal rules and exemptions.
Costs can move through contracts
CBAM’s financial obligation is calculated for each product using embedded emissions, the relevant certificate price, an adjustment reflecting EU Emissions Trading System free allocation, and any recognised carbon price effectively paid at origin. The €82.32 price is therefore not a percentage of import value or a fixed charge per tonne of metal; the amount depends on the product-level calculation.
Legal liability does not determine who ultimately absorbs the cost. An importer selling steel to a service centre may add a separate carbon surcharge to its invoice, which the service centre may then pass to a fabricator. The fabricator may recover only part of it from an automotive or machinery customer, while an intermediate processor could bear the difference if the final manufacturer has a fixed-price supply agreement. The ultimate customer is not automatically the party legally liable under CBAM.
Market structure and contract terms affect how the adjustment is divided between suppliers and buyers. Where EU buyers have several alternative suppliers, foreign producers or traders may have to absorb part of the cost to remain competitive. If material is scarce, technically qualified or tied to long-term contracts, downstream buyers may accept higher prices.
Assessing company exposure
European Central Bank research published in 2026 found that CBAM’s aggregate direct trade impact was small when averaged across all EU imports, while warning that effects could be material for individual products and exposures. The research does not mean that every company faces the same impact: exposure depends on the particular import and its place in the supply chain.
A company assessment needs to examine the importer of record, production emissions, sales terms, pricing benchmarks, credit exposure and the identity of the industrial customer. Separating the legal compliance obligation from competitive pressure on margins and purchasing decisions is necessary to identify who ultimately bears CBAM costs.
