Companies importing goods covered by the Carbon Border Adjustment Mechanism (CBAM) in 2026 will face four quarterly certificate prices rather than a single annual carbon price. The European Commission is assigning a separate price to each quarter of import, creating four distinct carbon-cost vintages within the first year of the definitive regime. This structure has implications for margin analysis, supplier comparisons, financial provisioning and year-end reporting.
The published certificate prices are €75.36 per tonne of CO₂ for the first quarter, €75.28 for the second and €82.32 for the third quarter. The fourth-quarter price is scheduled for publication on 4 January 2027. Certificate requirements for 2026 imports are calculated from the embedded emissions of goods imported during each quarter, with the corresponding quarterly price applied when certificates become available for purchase in 2027.
Import timing affects the carbon-cost calculation
The quarterly pricing structure means that importers with stable physical volumes can still experience changes in their carbon costs as deliveries fall into different pricing periods. Goods arriving in a higher-price quarter can generate a greater certificate cost even when product specifications and emissions intensity remain unchanged.
Conversely, switching to a supplier with lower verified embedded emissions may offset part of an increase driven by the EU carbon market. Procurement and finance teams therefore need to retain the import date and corresponding emissions information together instead of averaging the entire year’s exposure prematurely.
For importers, CFOs, procurement teams, carbon desks and auditors, this information already has a financial purpose. Exposure from 2026 imports is accumulating even though the first annual CBAM declaration and certificate-surrender deadline falls on 30 September 2027. Management reporting should provide a live connection between physical imports, estimated certificate requirements and anticipated cash outflows rather than relying solely on a year-end sustainability report.
Provision for costs before final emissions data arrive
CBAM creates different timelines for imports, emissions verification and certificate pricing. Goods may enter the EU before verified actual emissions data are available, while the applicable certificate price follows the quarterly pricing schedule. Companies therefore need a provisional emissions assumption and a process for updating the estimate when verified data become available.
Waiting for final verification before recognising exposure could leave businesses discovering substantial historical costs after customer prices have already been agreed. A disciplined accrual process allows finance teams to recognise expected liabilities while clearly identifying assumptions that remain provisional.
The control file should support a quarter-by-quarter reconciliation from customs entries to covered quantities, specific embedded emissions, the applicable free-allocation adjustment, any eligible deduction for carbon prices paid abroad and the relevant certificate price. This provides a consistent audit trail for financial provisioning and the subsequent CBAM declaration.
Quarterly pricing changes contract risk
The quarterly mechanism also affects commercial agreements. A fixed CBAM surcharge agreed at the beginning of the year can produce unexpected gains or losses for buyers and sellers if EU ETS prices change or verified emissions differ from initial estimates.
More robust contracts can specify a calculation formula linked to official certificate prices and agreed emissions data, with a subsequent adjustment when verification is complete. The agreement should distinguish provisional information from verified values and define which changes trigger a price true-up.
For example, a supplier might initially provide an estimated emissions intensity and later submit an accredited verification report. At the same time, the official certificate price may change between contract negotiation and settlement. Clearly defined adjustment mechanisms can reduce disputes and allow finance teams to estimate costs without waiting for every compliance input to be final.
Western Balkan exporters can make CBAM pricing more transparent
Exporters in Serbia and the wider Western Balkans can apply the same approach when preparing offers for EU customers. Instead of quoting a generic CBAM premium, they can show how the product’s verified emissions intensity affects the estimated certificate quantity, while identifying the official EU certificate price as an external market variable.
This distinction helps buyers understand which parts of the potential cost depend on supplier performance and which depend on the carbon market. It can also make supplier comparisons more consistent when products arrive in different quarters or use different emissions assumptions.
Finance teams should maintain separate quarterly cost records for 2026 and avoid relying on a single annual proxy before the final calculation is required. Contracts for late-year deliveries should specify how the relevant import quarter is determined and how subsequent emissions corrections or other adjustments are handled.
Connect customs, procurement and finance records
A practical implementation test is whether the company can explain its calculation to both an auditor and a commercial manager using the same underlying records. CBAM documentation should connect purchasing, production, customs and finance rather than operate as a separate compliance file.
Routine operational data, controlled assumptions and documented fallback methods allow companies to reflect changes in suppliers, transport routes, prices or legal requirements without rebuilding the calculation. The minimum decision file should link customs volumes, the emissions basis, certificate prices, expected cash timing and contractual cost pass-through, while identifying who approves each assumption.
A fallback should also be documented where the preferred emissions treatment cannot be substantiated. Although the alternative may be commercially less favourable, defining it early reduces the risk of discovering the actual exposure only when a verifier, customs authority or authorised declarant challenges the claim.
Consistent records make later price adjustments, verification changes and management reporting easier to defend. As CBAM’s financial effects grow, preventable evidence gaps risk becoming recurring costs.
The first definitive CBAM year is demonstrating that importers must manage both the emissions content of their goods and the timing of their arrival. With four quarterly certificate prices, the quarter of import is now an important variable in carbon-cost and invoice economics.
