EU CBAM Certificate Surrender Explained (2026–2027) - Part I
- CBAM Research Team
- Aug 5
- 30 min read
Updated: Aug 6
Quarterly Certificate Requirements, Annual True-Up and Compliance Guide
Scope and Disclaimer
This report is produced by CBAM Journal, operated by Sekason Research Limited (Company No. 14339910), London. It is provided for general information and research purposes only. It does not constitute legal, financial, investment, engineering, or safety-certification advice. Nothing in this report should be relied upon as the basis for any compliance decision without independent professional verification. Named companies and organisations are referenced for illustrative purposes only; their inclusion does not constitute endorsement. Company-attributed figures are reproduced as stated and have not been independently verified by CBAM Journal. Readers must not rely on this report as a substitute for professional advice specific to their own circumstances.
Full terms: cbamjournal.com/disclaimer.
1. Executive Summary
Executive Findings
FINDING: EU CBAM certificate sales begin on 1 February 2027, with the first annual declaration and certificate surrender for 2026 imports due by 30 September 2027 under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.
SO WHAT: Compliance Managers who have not established certificate purchasing, quarterly monitoring, and treasury provisioning processes by early 2027 will face a compressed, high-risk first compliance cycle with no grace period built into the statutory framework.
NOW WHAT: Establish governance, emissions forecasting, and treasury provisioning frameworks for certificate management by 1 October 2026, to ensure operational readiness before certificate sales open on 1 February 2027.
From 1 January 2026, the EU CBAM definitive regime imposes a direct financial obligation on authorised importers of steel, aluminium, cement, fertilisers, hydrogen, and electricity — accruing certificate costs from that date at a Q1 2026 price of €75.36 per tonne of CO₂, even though no cash payment falls due until the purchase window opens on 1 February 2027.
The first annual declaration and certificate surrender for 2026 imports must be completed by 30 September 2027, and from 2027 authorised declarants must maintain certificate holdings equal to at least 50% of their year-to-date embedded emissions at each of four quarter-end checkpoints: 31 March, 30 June, 30 September, and 31 December.
On 30 September 2027, two major obligations coincide on the same date — the Q3 quarterly holding checkpoint and the first annual certificate surrender — creating a concentration of compliance risk that requires active operational preparation throughout 2026.
That obligation is met through the purchase and surrender of CBAM certificates — one certificate per tonne of CO₂ equivalent in embedded emissions, priced against the EU Emissions Trading System (EU ETS).
Table 1: Executive Compliance Snapshot
Obligation | Deadline / Threshold | Governing Instrument |
Authorised CBAM Declarant status | Before importing above 50-tonne annual threshold | Regulation (EU) 2023/956, Article 5 |
Certificate sales open | 1 February 2027 | Regulation (EU) 2023/956, Article 20 |
≥50% quarterly certificate holding | 31 Mar / 30 Jun / 30 Sep / 31 Dec 2027 | Article 22 as amended by Regulation (EU) 2025/2083 |
First annual declaration + surrender (2026 imports) | 30 September 2027* | Regulation (EU) 2023/956, Article 22 |
Certificate cancellation — excess holdings | Date unconfirmed — see footnote † | Consolidated Regulation (EU) 2023/956 |
Non-surrender penalty | €100 per excess tonne of CO₂ | Enforcement provisions, Regulation (EU) 2023/956 |
* 30 September 2027 is the majority-source position (five sources). Two December 2025 sources state 31 August 2027. Verify against consolidated EUR-Lex Article 22 before using either date for planning.
† The certificate cancellation date is cited as 1 November in specialist operational guidance (CBAM Pulse, 15 July 2026); an EUR-Lex summary of Regulation (EU) 2023/956 cites 1 July. The discrepancy likely reflects the pre- vs post-amendment position under Regulation (EU) 2025/2083. Verify against consolidated Article 22 on EUR-Lex before planning certificate management activities around this date. Sources: Regulation (EU) 2023/956; Regulation (EU) 2025/2083.
Table 2: Key Dates at a Glance
Date | Regime | Milestone |
1 January 2026 | EU | Definitive regime begins; certificate costs accrue; no cash payment |
7 April 2026 | EU | Q1 2026 certificate price published: €75.36/tCO₂ |
1 January 2027 | UK | UK CBAM commences (Finance Act 2026) — tax/levy, not certificates |
1 February 2027 | EU | Certificate sales begin through common central platform (Article 20) |
31 March 2027 | EU | Q1 2027 holding checkpoint — ≥50% of YTD embedded emissions |
30 June 2027 | EU | Q2 2027 holding checkpoint — ≥50% of YTD embedded emissions |
30 September 2027* | EU | First annual declaration + certificate surrender (2026 imports); also Q3 holding checkpoint |
Date unconfirmed — see footnote † | EU | Certificate cancellation — excess holdings without compensation (date: verify Article 22) |
31 December 2027 | EU | Q4 2027 holding checkpoint — ≥50% of YTD embedded emissions |
31 May 2028 | UK | First UK CBAM tax return and payment due (covering full year 2027) |
* 30 September 2027: majority-source position — verify at EUR-Lex Article 22. † Certificate cancellation date: CBAM Pulse (15 July 2026) cites [November]; EUR-Lex summary cites [July]. Verify consolidated Article 22 before planning around this date. Sources: Regulation (EU) 2023/956; Regulation (EU) 2025/2083; Finance Act 2026; CM Trade Law, 9 April 2026.
Table 3: Certificate Lifecycle Overview
Stage | Action | When |
1. Import | Import in-scope goods; record CN code, country, volume, embedded emissions | Ongoing from 1 Jan 2026 |
2. Emissions Forecast | Forecast certificate demand using verified actual or Commission default values | Monthly throughout 2026/2027 |
3. Certificate Purchase | Buy through common central platform at applicable quarterly (2026) or weekly (2027) price | From 1 February 2027 |
4. Quarterly Review | Confirm account holds ≥50% of YTD embedded emissions at each quarter-end | 31 Mar / 30 Jun / 30 Sep / 31 Dec |
5. Annual Declaration | Submit declaration covering previous calendar year imports through CBAM Registry | By 30 Sep of following year |
6. Certificate Surrender | Surrender certificates equal to net embedded emissions after adjustments | By 30 Sep of following year |
7. Repurchase | Apply for repurchase of surplus certificates within conditions under consolidated Regulation | After surrender; subject to conditions |
8. Cancellation | Excess certificates cancelled without compensation (date: verify Article 22 on EUR-Lex) | Annually — verify date |
Sources: Regulation (EU) 2023/956, Articles 20–24; CBAM Pulse, 15 July 2026.
2. Regulatory Context
From Transitional Reporting to Financial Compliance
FINDING: The EU CBAM definitive regime began on 1 January 2026, converting a reporting-only obligation into a financial compliance mechanism under which authorised declarants must purchase and surrender CBAM certificates reflecting embedded emissions in imported goods.
SO WHAT: Importers who treated the 2023–2025 quarterly reporting period as the full extent of their CBAM obligation now face a structurally different requirement: accruing certificate costs throughout 2026 and meeting a cash payment obligation from February 2027.
NOW WHAT: Compliance Managers must audit 2026 import volumes and embedded emissions data by 31 December 2026 to establish the certificate demand baseline for the first surrender cycle.
The CBAM transitional period imposed a reporting obligation with no financial consequence: between 1 October 2023 and 31 December 2025, importers submitted quarterly embedded-emission reports but purchased no certificates and made no payments. The financial consequences of non-compliance in that period were limited compared to the definitive regime.
From 1 January 2026, the position changed fundamentally. The CBAM definitive regime imposes a direct financial obligation: for every tonne of CO₂ equivalent embedded in imported goods above the de minimis threshold of 50 tonnes net mass per importer per calendar year, an authorised CBAM declarant must hold and ultimately surrender a corresponding CBAM certificate. The obligation is statutory, not discretionary.
The transition also introduced third-party verification as a mandatory requirement. Importers cannot submit a declaration based on unverified internal estimates. Where verified actual data is unavailable, they may use Commission-published default values — but those defaults carry an upward mark-up under Implementing Regulation (EU) 2025/2621, creating a direct financial incentive to invest in verified actual data.
Table 4: Transition vs Definitive Regime Comparison
Feature | Transitional Period (2023–2025) | Definitive Regime (from 2026) |
Reporting basis | Quarterly emissions reports | Annual declaration with verified emissions data |
Financial obligation | None — reporting only | Certificate purchase and surrender |
Certificate purchase | Not required | Required; sales open 1 February 2027 |
Third-party verification | Not mandatory | Mandatory for annual declaration |
De minimis threshold | €150 per consignment (repealed) | 50 tonnes net mass per importer per calendar year |
Non-compliance penalty | Limited financial exposure | €100 per excess tonne CO₂; up to 5× for unauthorised imports |
Sources: Regulation (EU) 2023/956; Regulation (EU) 2025/2083; Reed Smith LLP, 27 October 2025.
The Legal Framework
FINDING: The certificate purchasing and surrender mechanism is governed by Articles 20–24 of Regulation (EU) 2023/956, as consolidated and amended by Regulation (EU) 2025/2083, with certificate pricing published under Article 21 and the common central platform established under Article 20 for sales from 1 February 2027.
SO WHAT: Compliance obligations under this framework are statutory — failure to purchase and surrender certificates by the annual deadline triggers a mandatory penalty of €100 per excess tonne of CO₂ with no discretionary waiver in the current consolidated text.
NOW WHAT: Map each internal compliance process to the relevant article of Regulation (EU) 2023/956 by 31 December 2026 to ensure no obligation is mischaracterised as guidance.
Certificate purchase, holding, surrender, and cancellation obligations each derive from a distinct legislative instrument under the EU CBAM framework — making it essential for Compliance Managers to distinguish the primary regulation from its implementing acts, and legally binding obligations from operational guidance that may evolve. The core legal structure is set out in Table 5.
Table 5: Legal Instruments Matrix
Instrument | Purpose | Key Provisions for Certificate Management |
Regulation (EU) 2023/956 | Primary CBAM Regulation — scope, obligations, declarant status, certificates | Articles 2–4 (scope); Articles 5–9 (declarant); Articles 20–24 (certificates) |
Regulation (EU) 2025/2083 | Omnibus amendment — revised timelines, reduced quarterly threshold, deferred certificate sales | Amends Articles 20, 22; moves surrender deadline; reduces threshold from 80% to 50% |
Implementing Regulation (EU) 2025/2548 | Certificate pricing — quarterly average in 2026; weekly from 2027 | Price publication schedule and calculation methodology |
Implementing Regulation (EU) 2025/2621 | Default values and mark-up schedule | +10% (2026), +20% (2027), +30% (2028+) most sectors; +1% fertilisers |
Annex II (Regulation (EU) 2023/956) | Sectors subject to direct emissions only | Iron and steel, aluminium, hydrogen — direct emissions only; indirect electricity excluded |
Sources: EUR-Lex summary; CM Trade Law, 9 April 2026; CBAM Pulse, 15 July 2026.
What Changed Under the 2025 Amendments
FINDING: Regulation (EU) 2025/2083 introduced three confirmed material changes to the original CBAM framework: it moved the annual declaration and surrender deadline to 30 September of the following year; deferred certificate sales to 1 February 2027; and reduced the quarterly holding threshold from 80% to 50% of embedded emissions. The certificate cancellation date requires separate verification against consolidated Article 22 on EUR-Lex.
SO WHAT: Importers relying on pre-amendment guidance — which specified a 31 May surrender deadline and an 80% quarterly holding threshold — will reach incorrect conclusions about cash-flow requirements and year-round certificate balancing obligations.
NOW WHAT: Update all internal compliance calendars, training materials, and treasury models to reflect the amended timetable by 1 January 2027, when UK CBAM also commences.
The 2025 amendments represent the most significant structural change to the CBAM framework since the definitive regime was first designed. Several provisions in force as recently as late 2024 have been superseded. Compliance Managers using briefing materials produced before Regulation (EU) 2025/2083 came into force risk operating against a superseded compliance model.
The quarterly holding threshold reduction from 80% to 50% has a direct cash-flow benefit: importers need fewer pre-purchased certificates at each quarter-end, reducing working capital requirements at any given point in the compliance year. The deferral of certificate sales from 1 January 2026 to 1 February 2027 means no cash outflow for certificates occurs in 2026, though the financial liability accrues from 1 January 2026 and must be recognised commercially and for accounting purposes throughout the year.
Table 6: Original Regulation vs Amended Regulation (EU) 2025/2083
Provision | Original Regulation | As Amended by Regulation (EU) 2025/2083 |
Annual surrender deadline | 31 May of following year | 30 September of following year* |
Certificate sales start date | 1 January 2026 | 1 February 2027 |
Quarterly holding threshold | 80% of embedded emissions | 50% of embedded emissions |
Certificate cancellation | 1 July annually (EUR-Lex summary) | [Verify date against consolidated Article 22] |
De minimis threshold | €150 per consignment (repealed) | 50 tonnes net mass per importer per calendar year |
* Deadline conflict: Lexology and BDO (both 22 December 2025) state 31 August 2027 — likely an earlier draft superseded by the finalised consolidated text. Verify against EUR-Lex consolidated Regulation (EU) 2023/956, Article 22, before publication. Cancellation date: EUR-Lex summary cites 1 July; CBAM Pulse (15 July 2026) cites a post-amendment date. Verify both against consolidated Article 22.
3. Compliance Obligations
Becoming an Authorised CBAM Declarant
FINDING: Under the definitive regime, only authorised CBAM declarants may purchase and surrender CBAM certificates; importers whose annual imports of in-scope goods fall below the 50-tonne net mass per calendar year de minimis threshold are exempt from authorisation, annual declarations, and certificate obligations.
SO WHAT: Any importer above the 50-tonne threshold that has not obtained authorisation cannot undertake compliant imports and faces penalties of up to five times the standard non-surrender rate under the enforcement provisions of Regulation (EU) 2023/956.
NOW WHAT: All importers of CBAM goods above the 50-tonne annual threshold must complete the authorisation process through the CBAM Registry before undertaking any imports subject to the definitive regime from 1 January 2026 onwards.
An importer without authorised CBAM declarant status cannot legally purchase certificates, submit a valid annual declaration, or surrender certificates against their embedded-emissions liability — making authorisation the foundational prerequisite for every downstream compliance obligation under the definitive regime.
The de minimis threshold was restructured by Regulation (EU) 2025/2083. The original €150 per consignment threshold has been repealed and replaced with a volume-based annual threshold of 50 tonnes net mass per importer per calendar year. An importer who brings in many small consignments can no longer rely on the per-consignment exemption: what matters is cumulative annual import volume. Importers whose total annual in-scope imports remain below 50 tonnes are exempt from all certificate obligations.
Authorisation must be obtained through the CBAM Registry. Compliance Managers must confirm their organisation's authorisation status before the first certificate purchase window opens on 1 February 2027.
Table 7: Authorisation Process Flow
Step | Action | Function |
1 | Identify all in-scope goods by CN code and annual import volume | Customs / Compliance |
2 | Confirm whether cumulative annual imports exceed 50-tonne de minimis threshold | Compliance |
3 | Submit authorisation application through CBAM Registry to competent national authority | Compliance |
4 | Receive authorised CBAM declarant status confirmation | Compliance |
5 | Set up certificate account in CBAM Registry for purchasing and holdings monitoring | Compliance / Finance |
6 | Establish internal notification process for quarterly holding checkpoints and annual declaration | Compliance / IT |
Sources: Regulation (EU) 2023/956; BSI Group, 2026.
Purchasing CBAM Certificates
FINDING: CBAM certificates are sold through a common central platform from 1 February 2027, with the Q1 2026 price set at €75.36 per tonne of CO₂ — published by the European Commission on 7 April 2026 under Article 21 of Regulation (EU) 2023/956.
SO WHAT: Although physical certificate purchases cannot be made until February 2027, the financial cost of certificates covering 2026 imports is commercially and financially real from 1 January 2026 and must be provisioned in accounts throughout the year.
NOW WHAT: Compliance Managers must establish treasury provisioning for certificate costs based on 2026 embedded emissions no later than Q2 2026, with formal CFO budget approval before the purchase window opens on 1 February 2027.
Member States sell CBAM certificates through a common central platform (Article 20). The platform opened for sales on 1 February 2027, covering embedded emissions from goods imported from 1 January 2026. Certificates for 2026 imports are priced at the quarterly average EU ETS auction price for the quarter in which the goods were imported — not at the weekly price applicable from 2027.
The 2026 quarterly price sequence:
Q1 price published 7 April 2026 at €75.36/tCO₂; Q2 price published 6 July 2026; Q3 price published 5 October 2026; Q4 price published 4 January 2027 (dates per CM Trade Law, 9 April 2026). Each price applies to certificates for imports made in that quarter. A declarant purchasing in February 2027 to cover Q1 2026 goods pays the Q1 2026 price of €75.36/tCO₂, not the prevailing February 2027 weekly price.
The most significant near-term risk for Compliance Managers is the gap between financial accrual (January 2026) and cash payment (from February 2027). Organisations that fail to provision for certificate costs during 2026 will face a concentrated cash demand when the purchase window opens — at precisely the moment they are also finalising 2026 emissions data and preparing the annual declaration.
Table 8: Certificate Purchase Workflow
Step | Action | Timing |
1 | Retrieve quarterly certificate price from Commission publication (7 Apr / 6 Jul / 5 Oct 2026; 4 Jan 2027) | Each quarter |
2 | Calculate estimated certificate demand: import volume × embedded emissions/tonne × applicable quarterly price | Monthly update |
3 | Provision certificate costs in management accounts — recognise as financial liability from Q1 2026 | From Q1 2026 |
4 | Open purchase window — buy certificates through common central platform from 1 February 2027 | From 1 Feb 2027 |
5 | Monitor certificate account against quarterly holding requirements (≥50% of YTD embedded emissions) | Each quarter-end |
6 | Confirm final certificate demand after verification and adjustments; top up or confirm surplus before declaration | By Aug 2027 |
Sources: Regulation (EU) 2023/956, Articles 20–21; CM Trade Law, 9 April 2026; EY Global, 2026.
Managing the Quarterly Holding Requirement
FINDING: From 2027, authorised CBAM declarants must hold certificates equal to at least 50% of embedded emissions in all imports made since 1 January of the compliance year at each of four quarter-end checkpoints: 31 March, 30 June, 30 September, and 31 December.
SO WHAT: The 30 September checkpoint falls on the same date as the annual declaration and surrender deadline in the first compliance cycle, concentrating two major compliance obligations on a single date with no buffer between them.
NOW WHAT: Implement a monthly certificate balance reconciliation process aligned to embedded emissions forecasts and customs import data, with Q3 2027 holdings confirmed at least two weeks before 30 September 2027.
The quarterly holding rule is one of the most operationally demanding aspects of the definitive CBAM regime. At the end of each quarter, a declarant's certificate account must show holdings of at least 50% of the embedded emissions in all goods imported since 1 January of the compliance year.
The baseline for the 50% calculation is determined by either (a) Commission default values, applied without the upward mark-up for this purpose, or (b) the number of certificates surrendered the previous year for the same goods by CN code and country of origin.
The holding obligation takes account of the free-allocation adjustment. Certificates surrendered under the free-allocation offset reduce the 50% holding calculation, so declarants who are also EU ETS participants receiving free allowances relevant to their import stream have a lower net holding requirement. This is a significant planning consideration for steel and aluminium importers, where EU ETS free allocations are being progressively phased down.
The temporal coincidence of the 30 September Q3 checkpoint and the annual declaration deadline in the first compliance cycle is a structural risk. On that single date, a declarant must simultaneously confirm that its certificate account meets the 50% threshold and submit the annual declaration covering all 2026 imports with corresponding surrendered certificates. Treating these as independent deadlines to be managed sequentially will result in operational failure.
Table 9: Quarterly Certificate Balance Monitoring Dashboard (Template)
Quarter | YTD Imports (t) | Est. YTD Embedded Emissions (tCO₂) | 50% Holding Requirement | Certificates Held | Status |
Q1 2027 (31 Mar) | [Enter] | [Enter] | [Calculate] | [Enter] | Compliant / Deficit |
Q2 2027 (30 Jun) | [Enter] | [Enter] | [Calculate] | [Enter] | Compliant / Deficit |
Q3 2027 (30 Sep) | [Enter] | [Enter] | [Calculate] | [Enter] | Compliant / Deficit |
Q4 2027 (31 Dec) | [Enter] | [Enter] | [Calculate] | [Enter] | Compliant / Deficit |
Source: Regulation (EU) 2023/956, Article 22 (as amended by Regulation (EU) 2025/2083); CM Trade Law, 9 April 2026.
Preparing the Annual Declaration and Certificate Surrender
FINDING: The first annual CBAM declaration, covering all 2026 imports, and the corresponding certificate surrender must be completed by 30 September 2027 — the majority position supported by five sources including EY, CM Trade Law, Coolset, CBAM Pulse, and an EUR-Lex summary of Regulation (EU) 2023/956.
SO WHAT: An organisation that has not completed third-party verification, reconciled certificate balances, and applied free-allocation and carbon-price-paid adjustments before the declaration opens will face an operationally impossible preparation window in the final weeks before the deadline.
NOW WHAT: Commission third-party emissions verification for all 2026 import transactions no later than 30 June 2027 to allow a full quarter of declaration preparation and certificate sourcing before the September deadline.
The annual declaration submitted through the CBAM Registry must set out the total embedded emissions in all in-scope goods imported during the previous calendar year, broken down by CN code and country of origin. It must be based on verified data — either verified actual emissions certified by an accredited third-party verifier, or Commission-published default values. Where default values are used, the mark-up under Implementing Regulation (EU) 2025/2621 inflates the declared figure above actual embedded emissions.
Before the net certificate surrender obligation is calculated, two adjustments apply. First, any free allocation under the EU ETS relevant to the imported goods reduces the number of certificates required. Second, any carbon price effectively paid in the country of origin — for example, a verified domestic carbon tax or ETS charge — is deducted from the CBAM liability. Both adjustments require documentation and are subject to verification requirements.
On the deadline: two legal commentary sources (Lexology and BDO, both 22 December 2025) state the surrender deadline as 31 August 2027. Five later or primary-derived sources, including the EUR-Lex summary of the consolidated Regulation, state 30 September 2027. This report treats 30 September as the working position. Compliance Managers must verify the definitive date against the consolidated text of Article 22 on EUR-Lex before using either date for planning.
Table 10: Annual Compliance Calendar — Declaration and Surrender
Month | Activity | Function |
Jan–Mar 2027 | Purchase certificates for 2026 Q1 imports at €75.36/tCO₂; confirm Q1 quarterly holding (31 Mar) | Finance / Compliance |
Apr–Jun 2027 | Purchase certificates for 2026 Q2–Q3 imports; confirm Q2 holding (30 Jun); commission third-party verifier | Finance / Sustainability |
Jul 2027 | Complete third-party verification of 2026 embedded emissions; draft annual declaration | Sustainability / Compliance |
Aug 2027 | Internal audit of declaration; apply free-allocation and carbon-price-paid adjustments; reconcile certificate account | Compliance / Finance |
Sep 2027 | Submit annual declaration; surrender net certificates; confirm Q3 holding (30 Sep) — all on same date | Compliance |
Oct 2027 | Resolve post-surrender queries; archive documentation for minimum applicable retention period | Compliance |
Nov 2027 | Monitor certificate cancellation (verify date); confirm no incorrectly retained certificates cancelled | Finance / Compliance |
Dec 2027 | Confirm Q4 2027 quarterly holding (31 Dec); begin 2027 data consolidation for 2028 cycle | Compliance |
Sources: Regulation (EU) 2023/956; CM Trade Law, 9 April 2026; EY Global, 2026.
4. Key Dates and Deadlines
The Definitive Regime Compliance Timeline
FINDING: The EU CBAM definitive regime compliance calendar runs from 1 January 2026 through 1 February 2027 (certificate sales) to 30 September 2027 (first annual declaration and certificate surrender), with an annual certificate cancellation date requiring verification against the consolidated text of Regulation (EU) 2023/956, Article 22, on EUR-Lex.
SO WHAT: Each milestone is a legal trigger with financial or operational consequences — missing the February 2027 purchase window restricts access; missing the September surrender deadline triggers the €100/tCO₂ non-surrender penalty.
NOW WHAT: Create a board-approved compliance calendar incorporating every statutory milestone by 1 October 2026, with monthly executive reporting requirements assigned to named functions.
The definitive regime compliance timeline spans three calendar years — 2026, 2027, and 2028 — before the first full annual cycle is complete.
The milestones below are legally binding; missing any of them has direct consequences that cannot be remedied retrospectively.
Table 11: Master Compliance Timeline (2026–2028)
Date | Regime | Obligation | Regulation Reference |
1 Jan 2026 | EU | Definitive CBAM regime begins; certificate costs accrue; no cash payment yet | Regulation (EU) 2023/956 |
7 Apr 2026 | EU | Q1 2026 certificate price published: €75.36/tCO₂ | Article 21; Impl. Reg. (EU) 2025/2548 |
6 Jul 2026 | EU | Q2 2026 certificate price published (CM Trade Law, 9 Apr 2026) | Article 21; Impl. Reg. (EU) 2025/2548 |
5 Oct 2026 | EU | Q3 2026 certificate price published (CM Trade Law, 9 Apr 2026) | Article 21; Impl. Reg. (EU) 2025/2548 |
1 Jan 2027 | UK | UK CBAM commences (Finance Act 2026); first UK accounting period begins | Finance Act 2026 |
4 Jan 2027 | EU | Q4 2026 certificate price published (CM Trade Law, 9 Apr 2026) | Article 21; Impl. Reg. (EU) 2025/2548 |
1 Feb 2027 | EU | Certificate sales open through common central platform (Article 20) | Regulation (EU) 2025/2083, Article 20 |
31 Mar 2027 | EU | Q1 2027 quarterly holding checkpoint — ≥50% of YTD embedded emissions | Article 22 (as amended) |
30 Jun 2027 | EU | Q2 2027 quarterly holding checkpoint — ≥50% of YTD embedded emissions | Article 22 (as amended) |
30 Sep 2027* | EU | First annual declaration + certificate surrender (2026 imports); also Q3 2027 holding checkpoint | Article 22 (as amended) |
Date unconfirmed — see footnote † | EU | Annual certificate cancellation — excess holdings cancelled without compensation (date: verify Article 22) | Consolidated Regulation (EU) 2023/956 |
31 Dec 2027 | EU | Q4 2027 quarterly holding checkpoint — ≥50% of YTD embedded emissions | Article 22 (as amended) |
31 May 2028 | UK | First UK CBAM tax return and payment due (covering full year 2027) | Finance Act 2026 |
30 Sep 2028 | EU | Second annual declaration + certificate surrender (covering 2027 imports) | Article 22 (as amended) |
* See deadline conflict note in Section 3.
† Certificate cancellation date: CBAM Pulse (15 July 2026) cites a post-amendment date; EUR-Lex summary cites 1 July. Verify consolidated Article 22. Sources: Regulation (EU) 2023/956; Regulation (EU) 2025/2083; Finance Act 2026; CM Trade Law, 9 April 2026.
Quarterly Certificate Monitoring Cycle
FINDING: Authorised declarants face four certificate-holding checkpoints in 2027 — 31 March, 30 June, 30 September, and 31 December — at which holdings must cover at least 50% of embedded emissions in imports made since 1 January of that year.
SO WHAT: The 30 September checkpoint falls on the same date as the annual declaration and surrender deadline in the first compliance cycle, meaning Compliance Managers must simultaneously confirm quarterly holdings and complete the full annual declaration and certificate surrender.
NOW WHAT: Implement monthly certificate tracking from 1 January 2027 so that the dual 30 September obligation can be met without operational disruption.
The quarterly holding obligation operates on a cumulative year-to-date basis, not a quarterly increment basis. At 31 March 2027, a declarant must hold certificates equal to at least 50% of embedded emissions in all goods imported between 1 January 2027 and 31 March 2027. At 30 June 2027, the calculation references all goods imported between 1 January 2027 and 30 June 2027. The 50% threshold always references the full year-to-date position.
The 31 December checkpoint is the largest in absolute certificate terms for any given compliance year. The risk lies in front-loaded import years, where large early imports create significant certificate demand at the Q1 checkpoint before an organisation has fully established its purchasing rhythm. Monthly monitoring from January is the only reliable way to detect and correct this in time.
Table 12: Quarterly Compliance Dashboard (2027 Template)
Quarter | Checkpoint Date | YTD Cumulative Embedded Emissions | Min. Holding Required (50%) | Additional Note |
Q1 2027 | 31 March 2027 | [Jan–Mar 2027 imports] | [×50%] | First checkpoint after purchase window opens |
Q2 2027 | 30 June 2027 | [Jan–Jun 2027 imports] | [×50%] | -- |
Q3 2027 | 30 September 2027* | [Jan–Sep 2027 imports] | [×50%] | Annual declaration + 2026 surrender due same date |
Q4 2027 | 31 December 2027 | [Jan–Dec 2027 imports] | [×50%] | Largest holding checkpoint of the year |
Sources: Regulation (EU) 2023/956, Article 22; CM Trade Law, 9 April 2026. * Date: 30 September is the majority-source position — verify against EUR-Lex consolidated Article 22.
5. Financial Exposure and Risk
Certificate Economics
FINDING: The first CBAM certificate price under the definitive regime was published by the European Commission on 7 April 2026 at €75.36 per tonne of CO₂ for Q1 2026 imports; from 2027, prices shift to weekly publication under Implementing Regulation (EU) 2025/2548, introducing shorter-cycle pricing volatility.
SO WHAT: At €75.36/tCO₂, even moderate import volumes of carbon-intensive goods generate material certificate costs — the actual per-tonne product liability depends on embedded emissions, which vary significantly by sector, production route, and country of origin.
NOW WHAT: Develop quarterly financial forecasts modelling certificate cost at the prevailing EU ETS price for each active import stream by 31 December 2026, refreshed following each price publication.
The certificate cost structure is a straightforward multiplication: (verified embedded emissions per tonne of product) × (certificate price per tonne of CO₂). At the Q1 2026 price of €75.36/tCO₂, the total liability is entirely determined by the emissions intensity of the specific goods imported. A steel producer operating a blast-furnace/basic-oxygen-furnace (BF-BOF) route generates substantially higher direct CO₂ per tonne of crude steel than one using an electric arc furnace (EAF); at any given EU ETS price, the certificate cost per tonne of product is a direct function of that production-route difference.
The default-value mark-up schedule under Implementing Regulation (EU) 2025/2621 imposes an additional financial cost on importers who cannot provide verified actual data. For most CBAM sectors, the mark-up is +10% above actual embedded emissions in 2026, rising to +20% in 2027 and +30% from 2028 onwards. Fertilisers carry a distinct lower mark-up of +1%. The financial penalty compounds annually: at the Q1 2026 price of €75.36/tCO₂, the +10% default mark-up adds €7.54 per tonne of CO₂ in declared emissions; the +30% mark-up applicable from 2028 adds €22.61 per tonne of CO₂ at the same price. The total per-tonne product impact depends on the embedded-emission intensity of the specific goods imported.
From 2027, certificate prices are published weekly rather than quarterly under Implementing Regulation (EU) 2025/2548. This shortens the price-reference cycle from 13 weeks to 7 days, requiring treasury functions to monitor EU ETS price movements continuously rather than setting a quarterly budget figure and holding it for three months.
Table 13: Certificate Cost Model (Q1 2026 Price — €75.36/tCO₂)
Variable | Steel (BF-BOF) | Steel (EAF) |
Embedded direct emissions (tCO₂/tonne of product) | Source from Commission CBAM portal or Annex IV default | Source from Commission CBAM portal or Annex IV default |
Q1 2026 certificate price | €75.36/tCO₂ | €75.36/tCO₂ |
Certificate cost per tonne (verified actual) | [embedded emissions × €75.36] | [embedded emissions × €75.36] |
Default mark-up 2026 (+10% per Impl. Reg. (EU) 2025/2621) | [actual cost × 1.10] | [actual cost × 1.10] |
Default mark-up 2027 (+20%) | [actual cost × 1.20] | [actual cost × 1.20] |
Default mark-up 2028+ (+30%) | [actual cost × 1.30] | [actual cost × 1.30] |
The Commission CBAM portal ( https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en ) and Annex IV of Regulation (EU) 2023/956 contain the applicable default embedded-emission values required to complete this cost model. Compliance Managers should obtain the relevant tCO₂/tonne figure for each product category directly from those sources and apply the mark-up schedule above. Per-sector default embedded-emission intensities were not available from the authoritative Commission or EEA sources within this report's research scope. Sources for certificate price and mark-up: CM Trade Law, 9 April 2026; Implementing Regulation (EU) 2025/2621.
Under-Purchasing vs Over-Purchasing
FINDING: Certificates not surrendered by the annual deadline attract a penalty of €100 per excess tonne of CO₂; excess certificates held beyond the vintage window applicable under the consolidated Regulation are subject to cancellation without compensation annually — verify the cancellation date and vintage period against Article 22 on EUR-Lex.
SO WHAT: Both under-purchasing and over-purchasing carry direct financial consequences — under-purchasing risks the €100/tCO₂ non-surrender penalty, while over-purchasing locks capital in certificates that may be cancelled without reimbursement.
NOW WHAT: Adopt a rolling monthly purchase strategy sized against updated embedded emissions forecasts, with a formal review triggered whenever import volume changes exceed 10% from the baseline forecast.
The CBAM certificate system provides some flexibility through repurchase provisions, but that flexibility is constrained. After the annual surrender, declarants holding surplus certificates may request repurchase under conditions in the consolidated Regulation. However, certificates held beyond the vintage window specified in Article 22 are cancelled without compensation at the annual cancellation date — both the vintage period and the cancellation date require verification against the consolidated text of Regulation (EU) 2023/956, Article 22, on EUR-Lex before planning certificate management activities around them.
Under-purchasing presents a different risk profile. If the quarterly holding obligation is not met at any of the four checkpoints, the declarant faces enforcement scrutiny. If the annual declaration produces a certificate shortfall, the non-surrender penalty of €100/tCO₂ applies to each tonne of the shortfall. The penalty applies over and above the certificate purchase cost itself and creates no offsetting credit towards future obligations.
Table 14: Under-Purchasing vs Over-Purchasing Decision Matrix
Scenario | Compliance Risk | Financial Impact | Penalty Reference | Recommended Action |
Under-purchasing: quarterly shortfall | Fail quarterly 50% holding checkpoint | Enforcement scrutiny; obligation to purchase immediately | Article 22, Regulation (EU) 2023/956 | Monitor monthly; purchase to cover projected shortfall before quarter-end |
Under-purchasing: surrender shortfall | Annual declaration shows net certificate deficit | €100/tCO₂ for each tonne of shortfall at surrender | Enforcement provisions, Regulation (EU) 2023/956 | Complete internal audit and top-up purchases by 31 August 2027 |
Over-purchasing: surplus within window | Low — surplus repurchase permitted | Capital locked until repurchase; minor administrative cost | Consolidated Regulation, repurchase provisions | Apply for repurchase after surrender; monitor cancellation date |
Over-purchasing: certificates beyond vintage window | Certificates cancelled without compensation | Full face value of cancelled certificates written off | Article 22 (verify vintage period and cancellation date at EUR-Lex) | Track certificate vintage; apply for repurchase before cancellation date |
Unauthorised import above 50-tonne threshold | Regulatory breach — potential import refusal | Penalty up to 5× standard rate (up to ~€500/tCO₂) | Reed Smith, 27 Oct 2025 (enforcement provisions) | Confirm authorisation before importing any in-scope goods |
Sources: Regulation (EU) 2023/956; CBAM Pulse, 15 July 2026; Reed Smith LLP, 27 October 2025.
FINDING: Importers conducting CBAM imports above the 50-tonne threshold without authorisation face penalties of up to five times the standard €100/tCO₂ rate — a potential liability of up to €500 per tonne of CO₂ in the most severe enforcement scenario.
SO WHAT: The risk profile of EU CBAM certificate management spans five categories — authorisation, data, treasury, process, and audit — and a failure in any category can trigger financial penalties, import disruption, or declaration errors that compound across the annual cycle.
NOW WHAT: Complete a formal CBAM risk assessment covering all five risk categories before the first certificate purchase window opens on 1 February 2027.
Table 15: Compliance Risk Register
Risk Category | Risk Description | Financial / Operational Impact | Mitigation |
Authorisation | Importing above 50-tonne threshold without authorised declarant status | Penalties up to €500/tCO₂ (5× standard rate); potential import refusal | Confirm authorisation status before any 2026 imports |
Data | Reliance on default values where verified actual data is available | Overpayment: default values carry +10–30% mark-up above actual (Implementing Regulation (EU) 2025/2621) | Engage suppliers for verified actual data; commission verifier by Q2 2027 |
Data | Supplier revises embedded emissions after declaration submitted | Declaration error; potential enforcement query; amended declaration may be required | Confirm all supplier data before declaration submission; retain version-controlled records |
Treasury | Failure to provision certificate costs during 2026 | Concentrated cash demand from Feb 2027; potential inability to purchase sufficient certificates | Recognise CBAM liability from Q1 2026; quarterly treasury forecasting |
Process | Quarterly holding falls below 50% at any quarter-end | Enforcement scrutiny; required to purchase additional certificates immediately | Monthly certificate balance monitoring; purchase trigger when balance approaches 55% floor |
Process | Certificates held beyond vintage window at annual cancellation date | Cancellation without compensation — full certificate value written off (verify date and period at EUR-Lex) | Track certificate vintage dates; apply for repurchase before annual cancellation |
Audit | Insufficient documentation for regulatory inspection | Regulatory enforcement action; documentation-failure penalty scenarios should be confirmed from implementing guidance | Maintain records for applicable minimum period; conduct annual internal audit by 30 June each year |
Non-surrender | Certificates surrendered fall short of net embedded-emissions liability | €100/tCO₂ for each tonne of shortfall at annual surrender deadline | Complete internal audit and certificate top-up by 31 August 2027 |
Sources: Regulation (EU) 2023/956; Reed Smith LLP, 27 October 2025; Coolset, 4 January 2026; Implementing Regulation (EU) 2025/2621.
6. Sector-Specific Impact Analysis
The six sectors covered by EU CBAM differ materially in their emissions profile, scope of the CBAM obligation (Annex II — direct emissions only; Annex I — broader scope), and verification infrastructure maturity. The sector comparison table provides an at-a-glance reference; each subsection addresses specific compliance implications for importers.
Table 16: Sector Impact Comparison
Sector | Annex | Emissions Scope | Default Mark-Up 2026 | Embedded Emissions (tCO₂/t) | Key Compliance Note |
Steel | II | Direct only | +10% | Source: Commission CBAM portal | BF-BOF vs EAF distinction critical for cost modelling |
Aluminium | II | Direct only (indirect/electricity excluded) | +10% | Source: Commission CBAM portal | Electricity source does not reduce CBAM liability under Annex II scope |
Cement | I | Direct | +10% | Source: Commission CBAM portal | Calcination creates high process emissions; non-EU producer data collection challenging |
Fertilisers | I | Direct | +1% (distinct) | Source: Commission CBAM portal | Lower default mark-up than other sectors; verification obligation unchanged |
Hydrogen | II | Direct only | +10% | Source: Commission CBAM portal | Production pathway (grey/blue/green) creates wide emissions range; verifier access issues |
Electricity | I | Embedded direct | +10% | Source: Commission CBAM portal | UK CBAM explicitly excludes electricity; EU obligation remains |
Per-sector default embedded-emission intensity figures (tCO₂/tonne) should be sourced directly from the Commission CBAM portal ( https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en ) or Annex IV of Regulation (EU) 2023/956. These values were not available from the authoritative Commission or EEA sources within this report's research scope. Sources for Annex classification and mark-up: Regulation (EU) 2023/956, Annexes I and II; Implementing Regulation (EU) 2025/2621.
Steel
FINDING: Under Annex II of Regulation (EU) 2023/956, steel imports are subject to EU CBAM on direct emissions only — indirect emissions from electricity consumption in the production process are excluded from the liability calculation.
SO WHAT: Steel importers sourcing from blast-furnace/basic-oxygen-furnace producers face materially higher CBAM exposure than those sourcing from electric arc furnace producers, because BF-BOF routes generate significantly higher direct CO₂ per tonne of crude steel.
NOW WHAT: Map all active steel supply chains to production route by 31 December 2026 to quantify direct-emission intensity per supplier and establish differentiated certificate purchasing requirements for the first 2027 cycle.
Steel is covered under Annex II, meaning the CBAM obligation applies to direct emissions only. The indirect CO₂ associated with electricity consumed in steel production is excluded. Certificate demand for a given steel import is therefore determined entirely by direct process emissions — primarily CO₂ from combustion of coal and coke in BF-BOF operations.
The production-route distinction between BF-BOF and EAF is financially material. BF-BOF steel, which uses iron ore reduced with coking coal, generates substantially higher direct CO₂ per tonne than EAF steel, which uses electricity to melt recycled scrap. Importers whose supply chains include BF-BOF producers face proportionally higher CBAM certificate demand.
Analysis reported by Sentra.world CEO Harsh Choudhry at a EUROMETAL webinar (January 2026) indicated that CBAM exposure could reach 10–20% of product cost for carbon-intensive steel once EU free allocation phases down.
Approximately 95% of India's CRCA exports and 80% of coated steel shipments are sold into Europe, creating significant exposure concentration for those categories. These figures are attributed to the Sentra.world/Kallanish webinar analysis as reported by EUROMETAL (22 January 2026) and have not been independently verified by CBAM Journal.
Aluminium
FINDING: Aluminium imports are covered under Annex II of Regulation (EU) 2023/956, with only direct emissions counted; indirect emissions from electricity used in smelting — which can represent the majority of aluminium's total carbon intensity — are explicitly excluded from the CBAM liability.
SO WHAT: The direct-emissions-only rule limits the CBAM certificate demand for aluminium compared to a full lifecycle calculation, but it also removes any financial signal under EU CBAM for importers to source preferentially from smelters powered by renewable electricity.
NOW WHAT: Confirm with each aluminium supplier by 31 December 2026 whether verified actual direct-emission data is available, since default values carry a +10% mark-up in 2026 rising to +30% from 2028 under Implementing Regulation (EU) 2025/2621.
Aluminium sits under Annex II alongside steel and hydrogen. For aluminium smelting, the Annex II scope limitation is significant: primary aluminium production through the Hall–Héroult electrolysis process is electricity-intensive, and the associated indirect emissions — derived from the carbon intensity of the supply grid — can account for the majority of an aluminium product's total lifecycle emissions. Under the current Annex II classification, those indirect electricity emissions fall outside the CBAM calculation.
An aluminium smelter powered by coal-fired electricity creates a substantial overall carbon footprint, but its CBAM liability reflects only the direct process emissions from the smelting operation. Importers of primary aluminium from such facilities should not assume their CBAM liability reflects the full emissions profile of the product.
The default embedded-emission intensity for aluminium imports is not confirmed by an authoritative Commission or EEA source within this report's research scope. Compliance Managers should obtain the applicable tCO₂/tonne default from the Commission CBAM portal (taxation-customs.ec.europa.eu) or Annex IV of Regulation (EU) 2023/956 before calculating their certificate demand.
Cement
FINDING: Cement imports are included within EU CBAM scope under Annex I of Regulation (EU) 2023/956 and are subject to certificate surrender based on embedded direct emissions in imported products; the applicable default embedded-emission intensity should be sourced from the Commission CBAM portal or Annex IV of Regulation (EU) 2023/956.
SO WHAT: Cement carries some of the highest direct process emissions of any CBAM-covered sector due to calcination — the decomposition of limestone to produce clinker — which releases CO₂ as an inherent chemical process irrespective of the energy source used.
NOW WHAT: Cement importers must prioritise supplier engagement to obtain Annex IV-compliant emissions data by 31 December 2026, given that default-value mark-ups increase to +20% above actual in 2027 under Implementing Regulation (EU) 2025/2621.
The default embedded-emission intensity for cement imports is not confirmed by an authoritative Commission or EEA source within this report's research scope. Compliance Managers should obtain the applicable tCO₂/tonne default from the Commission CBAM portal or Annex IV of Regulation (EU) 2023/956 before calculating their certificate demand for cement imports.
Cement production is characterised by a specific emissions profile that differs from metals: the primary source of CO₂ is not combustion, but calcination — the high-temperature decomposition of calcium carbonate (limestone) to produce calcium oxide (clinker). This chemical reaction releases CO₂ as an unavoidable byproduct regardless of the fuel or energy source used in the kiln. Cement importers cannot substantially reduce CBAM liability by switching to renewable energy at the production facility.
Third-party emissions verification for non-EU cement producers presents practical challenges. Clinker production facilities in major cement-exporting countries may not have implemented the continuous monitoring systems required to produce Annex IV-compliant verified actual emissions data. Where verified data is unavailable, the +10% mark-up in 2026, rising to +30% from 2028, creates a compounding financial cost under Implementing Regulation (EU) 2025/2621.
Fertilisers
FINDING: Fertiliser imports are subject to EU CBAM under Annex I of Regulation (EU) 2023/956, with a distinct default-value mark-up of +1% above actual embedded emissions under Implementing Regulation (EU) 2025/2621 — compared to +10% for most other CBAM sectors in 2026, and subject to the same 30 September 2027 annual declaration deadline.
SO WHAT: The substantially lower default mark-up for fertilisers reduces the financial penalty for importers who cannot provide verified actual data in the near term, though it does not remove the verification requirement for importers seeking accuracy in their annual declaration.
NOW WHAT: Fertiliser importers must complete the authorisation process and submit annual declarations by 30 September 2027, regardless of the lower default mark-up premium.
Fertilisers — primarily nitrogenous fertilisers such as urea, ammonium nitrate, and nitric acid — are covered under Annex I. The embedded emissions in fertiliser production are dominated by the Haber–Bosch process for nitrogen fixation, which is natural-gas-intensive and generates significant CO₂ both from combustion and from the process chemistry. Nitric acid production also produces nitrous oxide (N₂O), a potent greenhouse gas with high global warming potential.
The +1% default-value mark-up for fertilisers under Implementing Regulation (EU) 2025/2621 is structurally distinct from the standard schedule. A fertiliser importer using Commission default values pays only marginally more than the actual embedded-emission cost. This contrasts sharply with steel and cement, where the 10–30% mark-up creates a strong financial incentive to invest in verified actual data collection.
The default embedded-emission intensity for fertiliser imports is not confirmed by an authoritative Commission or EEA source within this report's research scope. Compliance Managers should obtain the applicable tCO₂/tonne default from the Commission CBAM portal or Annex IV of Regulation (EU) 2023/956.
Hydrogen
FINDING: Hydrogen imports are included within EU CBAM scope under Annex II of Regulation (EU) 2023/956, subject to liability on direct emissions only; production pathways — grey, blue, and green — generate radically different embedded direct emissions, requiring pathway-specific verification before any certificate demand can be calculated.
SO WHAT: The EU hydrogen supply chain presents greater verification complexity than established sectors because third-party verifier access to non-EU production facilities is not yet standardised and the Commission's default-value methodology for hydrogen is not yet fully operational.
NOW WHAT: Importers of hydrogen should engage third-party verifiers with hydrogen production methodology experience by 30 June 2027 to allow adequate time for verification before the first surrender deadline.
Hydrogen is classified under Annex II, limiting the CBAM obligation to direct emissions. The verification challenge is more complex than for established commodity sectors: embedded direct emissions vary by orders of magnitude depending on the production pathway. Grey hydrogen (steam methane reforming without carbon capture) carries high direct emissions. Blue hydrogen (with carbon capture) has substantially lower direct emissions. Green hydrogen (electrolysis with renewable electricity) has near-zero direct emissions.
A CBAM declarant importing hydrogen must obtain verified actual emission data specific to the production pathway and installation. The verification methodology under Annex IV requires installation-specific data that many non-EU hydrogen producers do not yet routinely collect. Where verified actual data is unavailable, Commission default values apply with the standard +10% mark-up in 2026.
Default embedded-emission figures for hydrogen by production pathway are not confirmed by an authoritative Commission or EEA source within this report's research scope. Compliance Managers should obtain the applicable values from the Commission CBAM portal or Annex IV of Regulation (EU) 2023/956; the Commission's methodology is expected to differentiate between production pathways given the wide range of emissions profiles involved.
Electricity
FINDING: Electricity imports remain within EU CBAM scope under Annex I of Regulation (EU) 2023/956; UK CBAM explicitly excludes electricity from its sector coverage under the Finance Act 2026, creating a direct structural divergence in obligations for importers operating across both regimes.
SO WHAT: EU importers of electricity from non-EU grids face CBAM certificate obligations on embedded emissions in imported electricity, whereas UK importers of electricity face no equivalent UK CBAM charge — creating different cost structures for the same commodity depending on the destination market.
NOW WHAT: EU electricity importers must establish embedded-emissions tracking and certificate purchasing protocols by 1 February 2027; UK importers of electricity should confirm their exclusion under the Finance Act 2026 by 1 January 2027.
Electricity is covered under Annex I of Regulation (EU) 2023/956. The emissions calculation for electricity is based on the embedded CO₂ content of the electricity at the point of import — which depends on the generation mix in the exporting country or grid zone at the time of transfer.
The UK position is structurally different. The Finance Act 2026 explicitly excludes electricity from UK CBAM scope. An importer bringing electricity across the UK border faces no CBAM tax or levy. This creates a direct divergence: the same physical import of electricity carries a CBAM compliance burden in the EU but no equivalent burden in the UK. Compliance Managers operating across both markets must maintain separate compliance models for electricity and must not assume that the UK CBAM position mirrors the EU position.
Default embedded-emission figures for electricity imports by exporting grid zone are not confirmed by an authoritative Commission or EEA source within this report's research scope. EU electricity importers should obtain the applicable values from the Commission CBAM portal or Annex IV of Regulation (EU) 2023/956 before calculating their certificate obligations.
Continue Reading Part II: https://www.cbamjournal.com/post/eu-cbam-certificate-surrender-explained-2026-2027-part-ii
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