In the European Union, authorised importers remain legally responsible for Carbon Border Adjustment Mechanism (CBAM) declarations and certificate surrender, while market conditions and contracts can shift the economic cost along the supply chain. The European Commission published a third-quarter 2026 certificate price of €82.32 per tonne of carbon dioxide equivalent.
The EU imported €111.23 billion worth of products under existing CBAM codes in 2025. That customs value indicates potential commercial exposure, but does not establish who will surrender certificates, the amount payable or whether buyers can pass costs on to downstream customers. The authorised CBAM declarant is responsible for the relevant declaration and surrender, subject to applicable legal rules and exemptions.
Product calculations and cost pass-through
CBAM’s financial obligation is calculated for each product using embedded emissions, the relevant certificate price, an adjustment for free allocation under the EU Emissions Trading System (EU ETS), and any recognised carbon price effectively paid in the country of origin. The €82.32 price is one input: it is neither a universal surcharge per tonne of steel or aluminium nor a percentage of import value.
Legal responsibility does not determine who ultimately bears the cost. An importer selling steel to a service centre may add a separate carbon surcharge to its invoice, which the service centre may pass to a fabricator. The fabricator may recover only part of that amount from an automotive or machinery customer; an intermediate processor could bear the difference if the final manufacturer has a fixed-price supply agreement. The ultimate customer is not automatically legally liable under CBAM.
Market conditions shape company exposure
Market structure affects how suppliers and buyers divide the adjustment. If EU buyers have several alternative suppliers, foreign producers or traders may have to absorb part of the cost to remain competitive. When material is scarce, technically qualified or tied to long-term contracts, downstream buyers may accept higher prices.
European Central Bank research published in 2026 found that CBAM’s aggregate direct trade impact was small when averaged across all EU imports, while warning that effects could be material for individual products and exposures. Assessing a company’s exposure requires examining the importer of record, production emissions, sales terms, pricing benchmarks, credit exposure and the identity of its industrial customer. Separating legal compliance from competitive pressure on margins and purchasing decisions is necessary to identify who ultimately bears the cost.