If you import cement, fertilisers, iron & steel, aluminium, hydrogen or electricity into the EU, the definitive CBAM regime has applied since 1 January 2026. The reporting mechanics you may remember from the 2023–2025 transitional period have changed, and one question now dominates budgeting conversations: what will a CBAM certificate actually cost, and how many do we have to buy?
There is no single published price you can put in a spreadsheet today, because the certificate price is tied to future EU ETS auction results that have not happened yet. But the method is fully defined in law, and the inputs you control — tonnage and embedded emissions — are knowable now. This article walks through each factor in the cost, then shows a full worked calculation.
The three moving parts of a CBAM bill
Your certificate cost for a given year is the product of four things:
Two of these you influence directly: the mass you import and its embedded emissions. Two are set by the regulation and the market: the phase-in factor (fixed by year) and the certificate price (linked to the EU ETS). The following sections take each in turn.
1. The certificate price is linked to the EU ETS — and published, not fixed
A CBAM certificate represents one tonne of embedded CO₂e. Its price is set by the European Commission on the basis of EU Emissions Trading System (ETS) auction prices — it deliberately tracks what EU producers pay for their own emissions. There is no negotiated or catalogue price.
The averaging method differs by period:
- For 2026 emissions (the first certificates, sold from February 2027): a quarterly average of ETS auction prices. The Commission calculates each quarter's price in the first calendar week after the quarter ends. The first quarterly figure, covering Q1 2026, was published on 7 April 2026.
- From 2027 onwards: a weekly average of the closing prices at EU ETS auctions, published on the first working day of the following week.
Practically, this means your carbon exposure moves with the ETS market. If you already model an internal carbon price for other purposes, the current ETS auction level is the natural starting point — but treat it as a live input, not a locked one.
2. The phase-in factor: you do not pay for 100% of emissions yet
You do not surrender certificates for every tonne of embedded emissions from day one. The phase-in factor is the percentage of embedded emissions that must be covered by certificates in a given year. It rises over time, deliberately mirroring the phase-out of free allowances that EU ETS installations currently receive. This is what keeps imported and EU-made goods on a comparable footing during the transition.
The schedule below is set out in the CBAM Regulation and was not changed by the 2025 Omnibus simplification package — the Omnibus adjusted thresholds and deadlines (see the box further down), but the phase-in curve is unchanged:
| Year | Phase-in factor |
|---|---|
| 2026 | 2.5% |
| 2027 | 5% |
| 2028 | 10% |
| 2029 | 22.5% |
| 2030 | 48.5% |
| 2031 | 61% |
| 2032 | 73.5% |
| 2033 | 86% |
| 2034 onwards | 100% |
Two consequences worth planning for:
- 2026 obligations are small in cash terms — only 2.5% of embedded emissions are covered. The first bill, due September 2027, is more of a process rehearsal than a material cost for most importers.
- The jump from 2029 to 2030 is the steep one. The factor more than doubles (22.5% to 48.5%) in a single year. If you import carbon-intensive goods, that transition — not 2026 — is the window to have supplier emissions data, sourcing decisions and budgets in order.
3. Free allocation phase-out and the CBAM benchmark deduction
The phase-in factor is only half of the free-allocation story. EU producers in CBAM sectors still receive some free ETS allowances during the transition. To avoid double-charging imports for a cost that EU competitors are not yet fully bearing, the number of certificates you owe is reduced to reflect that residual free allocation.
This deduction is applied through CBAM benchmarks set per product (per CN code), under the free-allocation adjustment rules in the regulation (Article 31 and the related implementing act). In effect: as EU producers' free allowances shrink year on year, the deduction shrinks too, and the effective share of emissions you pay for climbs toward the full phase-in factor. The mechanism is designed so imported and domestic goods are treated symmetrically throughout the phase-out.
Worked example (illustrative figures)
Assume an importer brings in 600 tonnes of iron & steel in a compliance year, with an embedded emissions factor of 1.9 tCO₂e per tonne. We show the calculation at the 2028 phase-in factor of 10%, using an illustrative certificate price of €75/tCO₂e.
Step-by-step
Covered share (2028) = 1,140 × 10% = 114 tCO₂e
Certificate cost = 114 × €75 = €8,550 (before benchmark deduction)
The same 600 t at the 2026 factor (2.5%) would cover only 28.5 tCO₂e — about €2,138 at the same illustrative price. At the 2030 factor (48.5%) it would cover roughly 553 tCO₂e — about €41,467. Same imports, very different bills, driven almost entirely by the phase-in year.
Every euro figure above is illustrative. The €75 price is a placeholder, not a forecast — the real price will be the published ETS-linked average for the relevant period. The benchmark deduction (Section 3) will reduce the covered tonnes further once confirmed for your product. And the emissions factor should come from your supplier's verified data where available, rather than a default.
What the 2025 Omnibus changed — and what it did not
The 2025 CBAM Omnibus simplification package reshaped several procedural points that affect who is caught and when payments fall due. It did not change the phase-in factor curve or the ETS-linked pricing method above. The main changes relevant to cost planning:
| Item | Position under the definitive regime |
|---|---|
| De minimis threshold | A single 50-tonne annual mass threshold per importer replaces the old €150-per-consignment value rule. Electricity and hydrogen are excluded from this exemption — they are always in scope. |
| Certificate sales start | 1 February 2027, via the central platform, for 2026 imports. |
| First declaration & surrender | 30 September 2027 for 2026 imports (moved from the earlier 31 May date). |
| Quarterly holding requirement | Minimum certificates you must hold during the year reduced from 80% to 50% of cumulative embedded emissions — easing cash-flow timing. |
| Phase-in factor | Unchanged (2.5% in 2026 … 100% from 2034). |
If your planning still assumes the pre-Omnibus €150 value threshold or an 80% quarterly holding requirement, those numbers are out of date. Confirm the current values for your specific goods against the Commission's guidance before relying on any estimate.
Estimate your own certificate cost
Our CBAM Import Tracker runs entirely in your browser — import data never leaves your device. You log each import, watch the cumulative 50-tonne threshold, and get an embedded-emissions and certificate-cost estimate using the same tonnage × factor × phase-in × price logic shown above. The phase-in factor and certificate price are editable inputs, so you can model the ETS price as it moves and step through the yearly schedule rather than trusting a fixed number.
Open the CBAM Import Tracker →Related reading
New to the scope rules? See CBAM 50 tonnes exemption explained for how the annual mass threshold decides whether you owe certificates at all.
Key dates at a glance
- 1 January 2026 — definitive regime applies; obligations accrue on 2026 imports.
- 1 February 2027 — CBAM certificate sales open for authorised declarants.
- 30 September 2027 — first CBAM declaration and first certificate surrender, for 2026 imports.
- 2029–2030 — steepest phase-in step (22.5% to 48.5%); the key cost-planning window.
Sources
- European Commission — Carbon Border Adjustment Mechanism (certificate price basis: quarterly average in 2026, weekly average from 2027; first quarterly price published 7 April 2026; surrender by 30 September 2027)
- DEHSt (German Emissions Trading Authority) — CBAM certificates (price method and certificate sales starting February 2027)
- ICAP — EU adopts CBAM simplifications ahead of the compliance phase (Omnibus: 50-tonne threshold, 30 September 2027 deadline, 80%→50% holding requirement, February 2027 sales)
- Mayer Brown — EU adopts CBAM simplification regulation (Omnibus amendments; single 50-tonne mass threshold)
- Reed Smith — CBAM simplification comes into effect (electricity and hydrogen excluded from the de minimis exemption)
- Phase-in factor and free-allocation phase-out schedule: CBAM Regulation (EU) 2023/956 and the free-allocation adjustment implementing act (Article 31 benchmarks).
Regulatory facts verified against the above on 16 July 2026. CBAM rules and published figures change — confirm current values from the European Commission before relying on any estimate.