Importers pay about 2.5 per cent of CBAM emissions in 2026 because EU producers still retain 97.5 per cent of their EU ETS free allocation, and the free allocation adjustment mirrors that for imports. The share is not permanent: it climbs each year as free allocation is withdrawn, reaching 100 per cent in 2034.
The small payable share in 2026 is not a discount built into CBAM itself. It is a mirror of the EU Emissions Trading System. EU producers in CBAM sectors retain 97.5 per cent of their EU ETS free allocation in 2026 under the CBAM factor in Article 10a(1a) of Directive 2003/87/EC. Article 31 of Regulation (EU) 2023/956 requires an equivalent adjustment for imports, so covered goods face charges only on the share EU producers actually pay for.
Commission Implementing Regulation (EU) 2025/2620, adopted 16 December 2025 and applying from 1 January 2026, sets the methodology. It defines the specific embedded free allocation, SEFA: the free allocation embedded in one tonne of a good, expressed in tonnes of CO2e per tonne. The free allocation adjustment for a good equals its SEFA for the year times the total mass of that good imported during the reporting year. The declarant includes this adjustment in the annual CBAM declaration, and it reduces the certificates to be surrendered. With 97.5 per cent of allocation still free on the EU side, roughly 2.5 per cent of the gross certificate obligation remains payable in 2026.
The ramp to 100 per cent
The payable share rises every year as EU free allocation is withdrawn:
| Year | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | 2032 | 2033 | 2034 |
|---|---|---|---|---|---|---|---|---|---|
| Payable share | 2.5% | 5% | 10% | 22.5% | 48.5% | 61% | 73.5% | 86% | 100% |
Why a small 2026 figure multiplies
On unchanged embedded emissions, the payable share in 2030 is 48.5 per cent, nearly twenty times the 2026 figure. The certificate price is never fixed: in 2026 it is the quarterly average of EU ETS auction clearing prices, EUR 75.36 for Q1 and EUR 75.28 for Q2, moving to a weekly average from 2027. Certificate purchase and surrender begin on 1 February 2027, with the first annual declaration due 30 September 2027. Budgeting on the 2026 share alone therefore understates the exposure a supply contract carries into the 2030s.
GreenSutra’s consultants model certificate exposure across the full ramp as part of CBAM advisory, covering exposure assessment, embedded-emissions calculation and certificate cost planning. The CBAM cost calculator gives a first estimate of how the same import volume prices year by year.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2620 · European Commission CBAM