A steel exporter’s CBAM cost equals embedded emissions, marked up default or verified actual, multiplied by the EU ETS linked certificate price, a Q1 2026 average of EUR 75.36 per tonne CO2e, and a payable share rising from 2.5 percent in 2026 to 100 percent by 2034. An illustrative 500 tonne line pays about EUR 4,400 in 2026.
What sets the CBAM cost of a steel consignment
Three multipliers set the CBAM cost of any steel consignment entering the European Union: the embedded emissions figure, the certificate price and the payable share. The emissions figure is either the country of origin default value of Implementing Regulation (EU) 2025/2621, marked up 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028, or verified actual data from the producing installation. For Indian hot-rolled flat steel the base default of 4.28 tCO2e per tonne becomes 4.71 with the 2026 mark-up; the full India set is listed in the default values explainer. The certificate price tracks the EU ETS and averaged EUR 75.36 per tonne of CO2e in the first quarter of 2026. The payable share starts at 2.5 percent of embedded emissions in 2026 and reaches 100 percent by 2034. Steel is an Annex II good, so only direct embedded emissions are priced.
A worked illustration on India defaults
A single export line of 500 tonnes per year of hot-rolled flat steel on India default values shows how steeply the bill climbs.
| Year and basis | Payable share | Illustrative certificate bill |
|---|---|---|
| 2026, default path | 2.5 percent | about EUR 4,400 |
| 2034, default path | 100 percent | about EUR 209,652 |
| 2034, verified data at roughly half the default | 100 percent | about EUR 82,896 |
The default path climbs from about EUR 4,400 in 2026 to over EUR 200,000 in 2034 as the payable share reaches 100 percent. Verified actual data at roughly half the default cuts the 2034 bill by about 60 percent, from EUR 209,652 to EUR 82,896. The verified path is a data project: CBAM reporting has required actual rather than estimated data since 1 August 2024, and installation figures must be checked by an accredited verifier before they replace the default.
Why the cost arrives before the first invoice
Market pressure lands before the first certificate is surrendered. GTRI estimates price-cut pressure of 15 to 22 percent on Indian exporters, and India’s iron and steel exports to the EU fell 35.1 percent to USD 3.05 billion in FY24-25, well before the first annual declaration for 2026 imports falls due on 30 September 2027. Sizing the exposure early protects margin and market share. The CBAM cost calculator models the bill product by product, year by year; the CBAM discovery session maps the emissions data gap; and a CBAM consulting service prepares installation data for verification by an accredited verifier.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM