European steel importers must account for 2026 CBAM exposure in current commercial decisions even though certificates covering those imports will not be available for purchase until February 2027.
The financial phase of the Carbon Border Adjustment Mechanism began on 1 January 2026. However, the first annual declaration and certificate surrender covering 2026 imports are not due until 30 September 2027, creating a gap between when the liability arises and when it is financially settled.
CBAM certificate prices provide an early cost reference
The European Commission has set the CBAM certificate price at €75.36 per tonne of CO₂ equivalent for the first quarter of 2026 and €75.28/tCO₂e for the second quarter.
The price for the third quarter was scheduled for publication on 5 October and was not available by the edition’s 4 October cut-off. Certificate sales for the 2026 liability are due to begin in February 2027.
The published certificate prices do not translate directly into a charge for each tonne of imported steel. The eventual financial obligation depends on the covered embedded emissions, the applicable free-allocation adjustment and any eligible carbon price already paid in the exporting country.
Embedded emissions determine the eventual liability
Using a single percentage against the entire emissions footprint of a steel product can therefore produce an inaccurate estimate of the CBAM exposure. The calculation must reflect the emissions covered by the mechanism and the other applicable adjustments.
An RSM analysis published on 29 September also distinguishes between liabilities arising under the current system, their later cash settlement and possible future regulatory changes. Its discussion of a slower phase-out of free allocation relates to a policy proposal, rather than rules that have replaced the existing CBAM framework.
For purchasing departments, the timing creates a contractual issue over who bears any difference between an initial carbon-cost estimate and the eventual liability. A fixed-price resale agreement can leave an importer exposed if verified emissions data or the final calculation differs from the assumptions used when the steel was purchased.
Cash-flow timing does not remove economic exposure
Finance departments must likewise separate a cash-flow forecast from an accounting assessment. The fact that no CBAM certificate payment is required during 2026 does not mean that covered imports made during the year carry no economic cost.
The period before certificate sales begin instead provides additional time for importers to collect emissions evidence and arrange the necessary funding for the eventual settlement.
