CBAM entered its definitive phase in 2026, adding financial and commercial considerations beyond the obligation to purchase and surrender compliance certificates. Importers, industrial suppliers and financial institutions are required to account for embedded emissions when assessing commodity prices, negotiating supply agreements and calculating working-capital needs.
CBAM links emissions embedded in imported goods to the EU Emissions Trading System (EU ETS). The mechanism introduces carbon pricing into the landed cost of covered commodities, including steel, aluminium, cement, fertilisers, hydrogen and electricity.
EU ETS-linked CBAM certificate reference and 2026 price levels
The European Commission published CBAM certificate prices for 2026. For Q1 2026, the certificate price is EUR 75.36/tCO₂, while Q2 2026 is EUR 75.28/tCO₂. Q3 2026 is set at EUR 82.32/tCO₂.
In 2026, the certificate price is calculated using the quarterly average of EU ETS auction clearing prices. From 2027, the reference changes to a weekly average.
This structure exposes importers to movements in the European carbon market even when underlying commodity purchases are concluded under fixed-price agreements. As a result, the carbon component can change independently of the contractual price of imported steel, aluminium or other covered products.
CBAM also differentiates between CBAM certificates and EU ETS allowances. CBAM certificates are compliance instruments rather than freely tradable allowances, and importers cannot rely on a conventional secondary market in CBAM certificates to manage price exposure.
Treasury risk management using EU ETS financial instruments
The EU ETS provides market infrastructure for managing carbon-price risk through futures, options and over-the-counter structures. These instruments allow companies to lock in or limit exposure to movements in European allowance prices.
CBAM extends EU ETS pricing logic to companies that may not operate industrial installations within the European Union. Importers must consider how carbon-price movements affect future certificate requirements and the financial resources needed to meet obligations.
The distinction between compliance instruments and available hedging instruments is particularly relevant for treasury departments. Using EU ETS-linked financial products does not replace the obligation to calculate, acquire and surrender the required CBAM certificates.
Procurement comparisons based on embedded emissions and documentation
CBAM changes how European buyers compare suppliers during procurement. Decisions must consider more than quoted commodity prices, freight charges, tariffs and payment conditions.
The emissions profile of each imported product can affect final landed cost under CBAM. Buyers also need to assess whether a carbon price paid in the country of origin can be recognised under applicable CBAM rules and how many certificates will ultimately be surrendered.
A supplier with a lower headline price may become less competitive once embedded emissions and associated carbon costs are included in purchasing calculations. This affects negotiations between European importers and producers in third countries.
Verified emissions information and supporting documentation become commercial factors alongside product specifications, delivery schedules and payment terms. Procurement therefore incorporates emissions-related evidence into supplier selection processes.
Cross-department responsibilities for CBAM compliance and liquidity
The financial implications of CBAM are distributed across corporate functions that typically operate with separate responsibilities. Procurement manages physical supply agreements and supplier negotiations.
Sustainability teams handle emissions information, while customs departments oversee import declarations. Treasury manages exposure to EU ETS-linked carbon prices and foreign exchange movements, while finance provides liquidity required for certificate purchases and related obligations.
Without coordination among these functions, companies may leave material carbon-price exposure outside established purchasing and financial risk-management procedures. CBAM therefore requires integrated commercial governance connecting emissions accounting, customs compliance, procurement decisions and financial planning.
Carbon-adjusted landed-cost framework for supplier evaluation
An emerging approach involves assessing imports through a consistent carbon-adjusted landed-cost framework. This requires linking physical quantities of imported goods with embedded emissions, applicable free-allocation adjustments and any eligible deduction for carbon prices paid in the country of origin.
The calculation also incorporates expected CBAM certificate prices, foreign exchange exposure, financing costs and verification risks. For industrial buyers, it provides a basis for comparing suppliers using both conventional commodity costs and the financial consequences of embedded emissions.
For treasury and finance departments, the framework brings CBAM exposure into working-capital planning and carbon-price risk management. The definitive CBAM regime extends the influence of European carbon-market pricing into industrial trade, supplier relationships and corporate financial management.