EU CBAM certificates: prices, costs and the 2027 holding rule
Build a budget for 2026 imports, then calculate the separate quarterly holding requirement for goods imported in 2027.

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Budget for two obligations in 2027. First, buy certificates for covered imports made in 2026, using the price for each import quarter. Second, forecast the minimum certificate balance for 2027 imports at quarter end. The 50% holding rule applies to current-year imports. It does not set the price or halve the 2026 surrender.
Check your goods and threshold with the free EU and UK CBAM scope checker.
Which EU CBAM certificate price applies to my 2026 imports?
Use the customs import date to assign each line to a quarter. A June shipment and a July shipment can have different prices even if they came from the same supplier and you buy both sets of certificates in February.
- January to March 2026: €75.36 per certificate.
- April to June: €75.28.
- July to September: €82.32.
- October to December: leave the price provisional until the Commission’s scheduled publication on 4 January 2027.
From 2027 the Commission publishes weekly prices for the new regime. Keep the 2026 quarterly rates in your budget for 2026 goods. European Commission certificate prices.
How do I build a two-supplier budget?
Start with one row per supplier, product, origin and import quarter. Record the CN code, net tonnes, installation, emissions intensity, data source, free-allocation adjustment and any eligible carbon price paid abroad. Multiply goods weight by the applicable intensity to estimate embedded emissions. Apply the relevant adjustments before multiplying the resulting certificate requirement by price.
Supplier A, Q2 steel: suppose verified installation data and applicable adjustments give a requirement of 40 certificates. Budget 40 × €75.28 = €3,011.20.
Supplier B, Q3 steel: suppose the applicable default gives an adjusted requirement of 60 certificates. Budget 60 × €82.32 = €4,939.20. Together the two lines cost €7,950.40. These quantities are illustrative, after the free-allocation adjustment, with no foreign carbon-price deduction assumed.
When is verified supplier data worth pursuing?
If acceptable verified data reduced Supplier B’s requirement from 60 to 45 certificates, the saving for those imports would be 15 × €82.32 = €1,234.80. Compare that with the cost of verification and staff time. A supplier’s unverified estimate can help you model a scenario. Use it for the declaration only once it satisfies the actual-data requirements.
| Budget item | Amount |
|---|---|
| Using defaults: 60 certificates × €82.32 | €4,939.20 |
| Using verified data: 45 certificates × €82.32 | €3,704.40 |
| Illustrative external verification quote | €900.00 |
| Net saving before internal staff time | €334.80 |
For this shipment, verification breaks even at €1,234.80 in total additional costs. With a €900 quote, you have €334.80 left to cover staff time. Ask for installation data first where the expected saving on covered imports can justify obtaining and verifying it.
For steel and aluminium, the mark-up on the default emissions value is 10% for 2026, 20% for 2027 and 30% from 2028. It changes the emissions input used in the calculation. For example, a base value of 2 tonnes CO₂e per tonne of steel becomes 2.2 in 2026. EU default-value tables by product and origin. Use the Commission’s corrected tables and the right year. Check whether the published figure already includes the applicable mark-up before adjusting it. Actual data can also produce a higher result. Official defaults, benchmarks and verification guidance.
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How does the 50% CBAM certificate holding rule work?
For an importer already subject to the quarterly requirement, the first quarter-end is 31 March 2027. Calculate the minimum balance using 2027 year-to-date covered imports and the Article 22 methodology. The calculation accounts for free allocation. Its default-value route excludes the mark-up used for annual default reporting.
For example, if the Article 22 calculation gives 80 certificate-equivalents for January to March, the minimum balance is 40 certificates. At the next quarter-end, recalculate on cumulative imports from January. Check when the holding obligation starts if you cross the annual mass threshold during the year. See Articles 20–22 and 31 of the EU CBAM Regulation.
What should finance request this month?
Ask the broker for imports by quarter and the purchasing team for the largest suppliers’ evidence. Put the 2026 surrender budget and the 2027 minimum balance on separate lines. Label each input verified, default or provisional so finance can see which supplier response would materially change the forecast.
EcoComply supports authorised-declarant applications, supplier outreach and declaration preparation, with submission under delegation. Reporting support starts at €1,500 per year. Get a free CBAM scoping assessment with your import volumes and markets.
CBAM guide for importers · EU and UK CBAM compared
Also selling into the UK? Use the UK CBAM importer checklist for its separate registration and tax tests.
Common questions
When can an importer buy EU CBAM certificates?
Sales open on 1 February 2027. For covered goods imported in 2026, the applicable price follows the quarter of import. The first annual declaration and surrender are due by 30 September 2027.
Does the 50% holding rule halve the annual bill?
The rule sets a minimum registry balance during the year. The annual surrender is calculated separately using the applicable emissions and adjustments.
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