CBAM certificates are electronic units, each equal to one tonne of embedded CO2e. They cannot be transferred or sold to another person. An authorised declarant buys them from the common central platform and surrenders them each year against its declared import emissions. They are priced on the EU ETS auction average and, where actual emissions are declared, reduced by any carbon price effectively paid in a third country.
What one CBAM certificate represents
CBAM certificates are the settlement instrument of the definitive regime, live since 1 January 2026 after a transitional reporting phase that ran from October 2023 to December 2025. Each certificate corresponds to one tonne of CO2e of embedded emissions in a covered import, and only an authorised CBAM declarant may buy and surrender them. The embedded emissions calculated in GreenSutra’s CBAM advisory are the starting point for how many certificates the yearly declaration requires.
How the price and quantity are fixed
The price is not fixed by the importer. It tracks the EU ETS, calculated on the weighted average of the auction clearing prices of EU ETS allowances, published as a quarterly average in 2026 and a weekly average from 2027. The published figures are EUR 75.36 per certificate for Q1 2026, EUR 75.28 for Q2 and EUR 82.32 for Q3, so the mechanism, not any single price, is what matters.
The declarant surrenders certificates for the embedded emissions minus the free allocation adjustment, and minus any carbon price deduction, never below zero. The adjustment mirrors the free allocation EU producers of the same good still receive. On default values it is the good’s CBAM benchmark, times the CBAM factor for the year, times the cross-sectoral correction factor, times the mass imported. The CBAM factor is 97.5 per cent in 2026 and falls each year; from 2034 nothing is deducted for free allocation. In 2026, 2.5 per cent of the benchmark is no longer deducted. That figure is not 2.5 per cent of the embedded emissions. Where actual emissions are declared, a carbon price effectively paid in a third country can be deducted, net of any rebate, with records certified by an independent person. The EU does not have to recognise the foreign scheme. Actual emissions, as opposed to default values, must be verified by an accredited verifier before they are declared.
Example: one tonne of Indian hot-rolled flat steel (CN 7208) imported in the third quarter of 2026 on default values. The default value of 4.280 tonnes of CO2e, with the 10 per cent mark-up, gives 4.708. The free allocation adjustment is 0.975 x 1.00 x 1.370, or 1.336. The declarant surrenders 4.708 minus 1.336, or 3.372 certificates, about EUR 278 at the third-quarter 2026 price of EUR 82.32.
| Obligation | Definitive-period rule |
|---|---|
| Purchase venue | Common central platform, open from 1 February 2027 |
| Annual surrender | By 30 September, the number of certificates set in the annual declaration |
| Minimum holding | From 2027, at the end of each quarter, certificates for at least 50 per cent of the embedded emissions imported so far that year, after the free allocation adjustment |
| Sell-back | Capped at the number the declarant was obliged to buy that year under the quarterly holding rule; request by 31 October |
| Cancellation | Certificates still held are cancelled without compensation on 1 November of the second year after purchase; those bought for 2026 imports on 1 November 2027 |
Buying, surrendering and selling back
The certificate lifecycle follows fixed steps across the compliance year:
- Certificates are bought from a common central platform, open from 1 February 2027.
- By 30 September each year the declarant surrenders the number of certificates set in the annual declaration; the first declaration, covering 2026 imports, is due 30 September 2027.
- A missing certificate carries the EU ETS excess emissions penalty for the year of import, which is EUR 100 per tonne of CO2e, raised in line with European consumer prices. The shortfall must still be covered.
- Unused certificates are cancelled without compensation on 1 November of the second year after purchase, and those bought for 2026 imports on 1 November 2027.
The certificate count is not fixed. Moving from marked-up default values to verified installation data lowers the emissions those certificates must cover where the plant’s actual emissions are below the default. The CBAM cost calculator estimates the certificate cost for a specific product, volume and import year.
Sources: Regulation (EU) 2023/956 · Regulation (EU) 2025/2083 · European Commission CBAM