Certificates and annual declaration
How CBAM certificates work, pricing (EU-ETS indexed), annual declaration, calendar and cost simulations by sector.
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Nature and operation
A CBAM certificate represents one tonne of CO2 equivalent of embedded emissions. It is the monetary unit of the CBAM system: the importer purchases certificates and surrenders them to cover the emissions of their imports.
The system operates as follows:
- The importer purchases certificates via the CBAM registry at the current weekly price
- The certificates are held in their account in the registry
- At the annual declaration date, the importer surrenders certificates corresponding to their net emissions
- Surplus certificates may be bought back by the Commission
Unlike EU-ETS allowances, CBAM certificates are not tradeable on a secondary market. They can only be purchased from and surrendered to the Commission through the registry. This design prevents speculation and ensures price alignment with the EU-ETS.
Certificate pricing
The price of CBAM certificates is set in accordance with Article 20 and Implementing Regulation 2025/2548.
Calculation method: The price equals the average closing price of EU-ETS allowances (auctions on the common exchange platform) during each calendar week. The price is published weekly by the Commission, typically on Friday for the preceding week.
2026 price range: EU-ETS allowance prices have fluctuated between EUR 60 and 80/tCO2 since 2024. CBAM certificate prices track this trend closely.
Impact of the CBAM factor: In 2026, the CBAM factor is 2.5% (beginning of the free allowance phase-out). The actual cost per tonne imported is therefore:
CBAM cost 2026 = Embedded emissions x Certificate price x 2.5%
Worked example (steel import):
- 1,000 tonnes of steel imported (blast furnace route)
- Embedded emissions: 2.1 tCO2/t
- Certificate price: EUR 70/tCO2
- CBAM factor 2026: 2.5%
- CBAM cost = 1,000 x 2.1 x 70 x 2.5% = EUR 3,675
The same calculation in 2034 (100% factor) would yield EUR 147,000 -- a 40-fold increase. This trajectory underscores the importance of early preparation.
Purchasing and holding certificates
Article 20 sets the purchasing rules:
- Certificates are purchased through the CBAM registry (not on a secondary market)
- Purchases are possible at any time during the year, at the current weekly price
- The CBAM declarant must hold by 31 December of each year a number of certificates corresponding to at least 80% of the embedded emissions from imports during the first three quarters
- This interim obligation ensures that declarants do not defer all purchases to the end of the year
Certificate management strategy: Since prices fluctuate weekly with EU-ETS auction results, a dollar-cost averaging approach (purchasing regularly throughout the year) can reduce price risk compared to large one-time purchases.
Certificate surrender
Article 22 and Regulation 2025/2621 define the surrender process:
- Surrender takes place as part of the annual CBAM declaration (by 31 May)
- The number of certificates surrendered must cover the total embedded emissions of imports from the previous calendar year, after deduction of carbon price paid in the country of origin and free allowance adjustment (see chapter 7)
- Certificates not surrendered by the deadline are not automatically forfeited, but penalties apply for any shortfall
Buyback of surplus certificates
Article 23 provides that the CBAM declarant may request the competent authority to buy back surplus certificates. The Commission buys back:
- Up to one-third of certificates purchased during the preceding year
- At the original purchase price of each certificate
- The buyback window is typically in June, after the 31 May surrender deadline
This mechanism provides flexibility: if imports decrease or actual emissions are lower than anticipated, the declarant can recover part of their investment. However, the one-third cap means that over-purchasing carries risk.
The annual CBAM declaration
Declaration content
Article 6 defines the content of the annual CBAM declaration, submitted by 31 May each year for imports from the previous calendar year:
- Quantities of goods: by CN code, by country of origin, by production installation
- Embedded emissions: direct and indirect emissions (where applicable) per product and per installation
- Calculation method: actual emissions or default values, with justification for the method chosen
- Carbon price paid in the country of origin (for deduction -- see chapter 7)
- Certificates surrendered: number of certificates corresponding to net emissions after deductions
- Verification report: attestation from the accredited verifier (see chapter 5)
The declaration is submitted electronically through the CBAM registry. The competent authority reviews the declaration and may request amendments or additional documentation within 4 months of submission.
Customs data transmission
Article 33 and Regulation 2025/2619 provide for the automatic transmission of relevant data by customs authorities to the CBAM registry:
- Authorised CBAM declarant number entered in the customs declaration
- CN codes of CBAM goods imported and released for free circulation
- Quantities and declared values
- Country of origin
- Date and customs office of release
This automatic data feed enables the registry to cross-check the annual declaration against actual import records. Discrepancies trigger review by the competent authority.
Annual calendar for the CBAM declarant
| Period | Obligation |
|---|---|
| January -- December (year N) | Import CBAM goods, maintain records, purchase certificates progressively |
| 31 December (year N) | Hold a minimum of 80% of certificates needed for the first 3 quarters' imports |
| January -- March (year N+1) | Collect emissions data from suppliers, engage accredited verifier |
| March -- April (year N+1) | Verification of emissions by the accredited verifier |
| By 31 May (year N+1) | Submit the annual CBAM declaration in the registry |
| 31 May (year N+1) | Surrender certificates corresponding to net emissions |
| June (year N+1) | Request buyback of surplus certificates (optional, max 1/3) |
Cost simulations by sector (2026 vs 2030 vs 2034)
The following tables illustrate the increasing financial impact of CBAM using indicative values. All calculations assume no carbon price deductions from the country of origin.
Steel (blast furnace, 1,000 tonnes imported)
| Element | 2026 (2.5%) | 2030 (48.5%) | 2034 (100%) |
|---|---|---|---|
| Embedded emissions | 2,100 tCO2 | 2,100 tCO2 | 2,100 tCO2 |
| Certificate price (est.) | EUR 70/tCO2 | EUR 80/tCO2 | EUR 90/tCO2 |
| Gross cost | EUR 147,000 | EUR 168,000 | EUR 189,000 |
| CBAM factor | x 2.5% | x 48.5% | x 100% |
| Net CBAM cost | EUR 3,675 | EUR 81,480 | EUR 189,000 |
| Surcharge per tonne | EUR 3.68/t | EUR 81.48/t | EUR 189/t |
Primary aluminium (500 tonnes imported)
| Element | 2026 (2.5%) | 2030 (48.5%) | 2034 (100%) |
|---|---|---|---|
| Embedded emissions | 8,250 tCO2 | 8,250 tCO2 | 8,250 tCO2 |
| Certificate price (est.) | EUR 70/tCO2 | EUR 80/tCO2 | EUR 90/tCO2 |
| Gross cost | EUR 577,500 | EUR 660,000 | EUR 742,500 |
| CBAM factor | x 2.5% | x 48.5% | x 100% |
| Net CBAM cost | EUR 14,438 | EUR 320,100 | EUR 742,500 |
| Surcharge per tonne | EUR 28.88/t | EUR 640.20/t | EUR 1,485/t |
Cement (2,000 tonnes imported)
| Element | 2026 (2.5%) | 2030 (48.5%) | 2034 (100%) |
|---|---|---|---|
| Embedded emissions | 1,700 tCO2 | 1,700 tCO2 | 1,700 tCO2 |
| Certificate price (est.) | EUR 70/tCO2 | EUR 80/tCO2 | EUR 90/tCO2 |
| Gross cost | EUR 119,000 | EUR 136,000 | EUR 153,000 |
| CBAM factor | x 2.5% | x 48.5% | x 100% |
| Net CBAM cost | EUR 2,975 | EUR 65,960 | EUR 153,000 |
| Surcharge per tonne | EUR 1.49/t | EUR 32.98/t | EUR 76.50/t |
Ammonia fertiliser (1,500 tonnes imported)
| Element | 2026 (2.5%) | 2030 (48.5%) | 2034 (100%) |
|---|---|---|---|
| Embedded emissions | 3,600 tCO2 | 3,600 tCO2 | 3,600 tCO2 |
| Certificate price (est.) | EUR 70/tCO2 | EUR 80/tCO2 | EUR 90/tCO2 |
| Gross cost | EUR 252,000 | EUR 288,000 | EUR 324,000 |
| CBAM factor | x 2.5% | x 48.5% | x 100% |
| Net CBAM cost | EUR 6,300 | EUR 139,680 | EUR 324,000 |
| Surcharge per tonne | EUR 4.20/t | EUR 93.12/t | EUR 216/t |
Annual CBAM calendar
Frequently Asked Questions
- How is the CBAM certificate price determined?
- The CBAM certificate price equals the weekly average closing price of EU-ETS allowances on the common auction platform. In 2026, it fluctuates around EUR 60-80 per tonne of CO2 equivalent. The price is published weekly by the European Commission.
- Can CBAM certificates be resold on a secondary market?
- No. CBAM certificates are not tradeable on a secondary market. They are purchased from the Commission via the CBAM registry and can only be surrendered or bought back (up to one-third) by the Commission. This design prevents speculation and ensures price alignment with the EU-ETS.
- What happens if I do not surrender enough certificates by 31 May?
- Article 26 provides for a financial penalty equal to 3 times the average certificate price of the previous year, per tonne of CO2 not covered. In addition to the penalty, the missing certificates must still be surrendered. In case of repeated non-compliance, the authorised CBAM declarant status may be suspended or revoked.
- Is the CBAM cost tax-deductible?
- The cost of CBAM certificates constitutes a deductible business expense for corporate tax purposes, similar to customs duties or environmental levies. The exact accounting treatment may vary by Member State -- consult your tax advisor for the applicable treatment in your jurisdiction.
- Should I buy all certificates at once or spread purchases over the year?
- Spreading purchases over the year (dollar-cost averaging) is generally recommended to reduce exposure to price volatility. Since certificate prices follow EU-ETS auction results and fluctuate weekly, purchasing in regular intervals smooths the average cost. Remember: you must hold 80% of required certificates by 31 December for the first three quarters.