European companies importing steel, aluminium, fertilisers and other goods covered by the Carbon Border Adjustment Mechanism (CBAM) face two separate uncertainties when forecasting future compliance costs. One is the movement of EU carbon certificate prices, and the other is whether the phase-out of free emissions allowances for European industry changes.
The European Commission’s published CBAM certificate price reached €82.32 per tonne of CO₂ equivalent (tCO₂e) for the third quarter of 2026, compared with €75.28 in the second quarter. The quarterly increase was approximately 9.4%. In parallel, a separate Commission proposal could slow the withdrawal of free allocation under the EU Emissions Trading System (EU ETS), affecting the adjustment used to calculate importers’ carbon liabilities if adopted.
CBAM certificate prices: Q3 2026 level and shift in calculation frequency
The Commission published the third-quarter 2026 certificate price on October 5, 2026. Under the applicable pricing framework, the relevant quarterly price corresponds to the quarter in which goods entered the EU.
A change is scheduled for 2027, when certificate prices will be calculated weekly rather than quarterly. This is expected to affect how importers manage timing between customs clearance, certificate purchases and financial settlement.
The first purchases of CBAM certificates are scheduled to begin in February 2027. The first annual declaration and certificate surrender covering imports made during 2026 must be completed by September 30, 2027.
The time gap between importing goods and buying certificates creates working-capital and accounting considerations for businesses. Commercial invoices may be paid months before corresponding carbon certificates are acquired, requiring importers to estimate and manage liabilities before final settlement.
EU ETS reform proposal could alter CBAM free-allocation adjustment
Under legislation currently in force, the CBAM factor used in the free-allocation adjustment is 97.5% for 2026, then falling to 95% in 2027, 90% in 2028 and 51.5% in 2030. The existing phase-out schedule provides for complete withdrawal of free allocation in 2034.
The European Commission’s broader EU ETS revision proposal COM(2026)616, published in July 2026, would change that trajectory. Under the proposal, CBAM factors are set at 91.5% in 2028, 81% in 2029 and 59% in 2030, with complete removal of free allocation extended until 2038.
These figures remain proposals rather than rules already in force. Importers preparing commercial agreements are therefore expected to distinguish between the current legislative baseline and a scenario reflecting COM(2026)616 if it becomes law.
Emissions methodology and default values shape certificate requirements
The annual CBAM factor alone does not determine how many certificates are required for an imported product. Product-specific benchmark calculations, the relevant production route and eligible deductions also affect the final obligation.
The emissions calculation links chargeable emissions to certificate requirements. If a CBAM methodology results in 1.0 tonne of net chargeable emissions per tonne of imported goods, gross certificate exposure at the third-quarter 2026 price of €82.32/tCO₂e would be €82.32 per tonne of goods.
If net chargeable emissions were instead 0.4 tCO₂e per tonne of goods, gross exposure would be €32.93 per tonne of goods at the same certificate price level. The examples do not establish standard emissions factors for steel or aluminium; they illustrate how calculated chargeable emissions drive gross cost at a given market price.
Country-level default values published under CBAM implementing rules were corrected in July 2026. For many goods other than electricity, a markup of 10% applies in 2026, rising to 20% in 2027 and 30% from 2028, while fertilisers use a different markup of 1%.
Contracting and compliance: data responsibilities tied to import timing
The distinction between default values and verified actual emissions can affect compliance calculations. Establishing the relevant production installation and obtaining necessary verification evidence are identified as important elements of emissions assessment.
CBAM exposure begins with classification of imported goods under Combined Nomenclature (CN) rules that determine whether the mechanism applies. The production installation and verified emissions calculation then determine whether actual emissions can be used instead of a published default value.
The timing of customs release determines the relevant import period, while the declarant remains responsible for purchasing and surrendering required certificates and substantiating any eligible deduction for a carbon price paid abroad. Trading intermediaries and freight forwarders cannot replace missing production records or factory verification evidence simply by changing commercial invoices.
Contracts can specify CN classification, production site, reporting year, verifier details, deadlines for supplying and correcting emissions evidence, and how revised carbon prices are treated. Pricing clauses may allocate financial liability to an EU buyer while requiring suppliers to provide compliant documentation and compensate for deficiencies in required evidence.
Reconciling commercial charges with formal surrender figures
Banks evaluating credit facilities can test potential certificate cash outflows using scenarios that combine higher carbon prices with higher emissions levels. Such assessments are described as providing more detailed views than reliance on supplier environmental credentials alone.
Manufacturing, inventory and sales periods do not necessarily coincide with export timing into the EU. Importers must establish correct reporting periods and retain supporting documentation required by applicable rules; for goods imported in 2026, the relevant CBAM certificate price follows the applicable quarterly pricing arrangement.
A commercial agreement based only on a floating monthly carbon surcharge may fail to reflect statutory obligations if it does not match official certificate pricing and verified emissions results. Buyers and suppliers can instead agree to reconcile commercial charges after official certificate prices and verified emissions outcomes become available.
Auditors and bank credit teams can assess CBAM exposure by requesting a documented reconciliation between commercial estimates and formal certificate surrender figures. The reconciliation should identify tonnes of goods imported or megawatt-hours of electricity, production route, embedded emissions, benchmark adjustment, qualifying carbon-price deduction and resulting certificate requirement.
Each element can affect final obligations independently, so an unchanged carbon-market price does not guarantee unchanged CBAM liability when underlying emissions data or applicable adjustments change. Suppliers able to provide complete calculations and supporting documentation early may reduce year-end dispute risk compared with businesses relying on national averages or unverified sustainability reports.
For manufacturers in the Western Balkans, credible emissions records may support negotiations with EU purchasers seeking discounts linked to uncertainty around carbon costs. The distinction between imported product volumes, embedded tonnes of CO₂e and certificates ultimately required is described as central to reconciling commercial pricing with CBAM compliance.