The final phase of the CBAM begins.
DATE
15.7.2026
AUTHORS
TOPICS
Climate management
Strategy
Governance & regulation
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DATE
15.7.2026
AUTHORS
TOPICS
Climate management
Strategy
Governance & regulation
SHARE
As of July 2026
CBAM allowances will not be sold until February 1, 2027—yet the costs will still apply to every import made in 2026. Anyone importing steel, aluminum, cement, fertilizer, hydrogen, or electricity into the EU should know now how the certificate price is calculated, what deadlines apply, and what changes the draft Delegated Regulation on the sale of certificates—presented in July 2026—brings.
CBAM allowances are tradable credits that importers use to pay the CO₂ price for the emissions embodied in imported goods. One allowance corresponds to one metric ton of CO₂ equivalent. The Carbon Border Adjustment Mechanism (CBAM) thus aligns the carbon costs of imports with the burden borne by EU producers under the Emissions Trading System (EU ETS).
CBAM (Carbon Border Adjustment Mechanism): The EU’s CO₂ border adjustment mechanism under Regulation (EU) 2023/956. It requires importers of certain emission-intensive goods to pay for the carbon content of their imports via CBAM certificates starting January 1, 2026. The goal is to prevent carbon leakage—the shift of production to countries with less stringent climate regulations.
The definitive phase of the CBAM has been in effect since January 1, 2026. It replaces the reporting-only phase (2023–2025): Since then, imports have not only been subject to reporting requirements but have also had financial implications. The sectors covered include iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity.
The price of CBAM allowances is equal to the weighted average of the auction clearing prices of EU ETS allowances. For the year 2026, the European Commission will calculate and publish four quarterly prices—each in the first calendar week following the end of the quarter. The Q1 2026 price was set at €75.36/t on April 7, 2026, and the Q2 price was set at €75.28/t on July 6, 2026.
Each quarterly price applies to the allowances corresponding to the emissions from CBAM goods placed on the market during that quarter. Starting in 2027, the Commission will switch to a weekly published average price. The procedures for publishing prices are set forth in Implementing Regulation (EU) 2025/2548 of December 10, 2025.
PeriodPrice per metric tonPublished onCalculation basisQ1 202675.36 €April 7, 2026EU ETS auction prices Jan.–March 2026 (EEX)Q2 2026€75.28July 6, 2026EU ETS auction prices Apr.–June 2026 (EEX)Starting in 2027WeeklyWeeklyWeekly average of EU ETS auctions
Sales of CBAM allowances will begin on February 1, 2027. Sales and repurchases will take place via a central, shared platform where member states will offer the allowances. Authorized CBAM registrants will purchase the allowances retroactively for goods imported in 2026—meaning there is no obligation to purchase them in 2026 itself.
This sequence is important for liquidity planning: The obligation to pay arises upon import in 2026, but the actual cash outflow for the purchase of allowances does not begin until 2027. Companies should therefore set aside provisions this year for the CBAM liability due in 2026, even if no allowances have been purchased yet.
The draft Delegated Regulation specifies how the sale and repurchase of CBAM allowances will be conducted starting February 1, 2027. The European Commission released the draft for public consultation on July 9, 2026; comments may be submitted until August 6, 2026. The legal basis is Article 20(6) of the CBAM Regulation.
Among other things, the legislation addresses the timing, administration, structure, and amount of fees, as well as the purchase and buyback procedures. As of July 2026, the legislation has not yet been adopted; it is scheduled to take effect on February 1, 2027. Importers would be wise to wait for the final text before finalizing their internal procurement processes for certificates.
Four key parameters are decisive: the de minimis threshold of 50 metric tons per importer per year, the quarterly coverage reduced to 50 percent, the start of sales on February 1, 2027, and the first filing deadline on September 30, 2027. These values are largely based on the omnibus simplification (Regulation (EU) 2025/2083 amending (EU) 2023/956).
ThresholdRegulationSource/ReasonDe minimis threshold50 metric tons of CBAM goods per importer per year; no obligations below this threshold (replaces the previous €150 shipment limit)Omnibus (EU) 2025/2083Quarterly CoverageRequirement to cover 50% of embedded emissions per quarter (previously 80%)Omnibus (EU) 2025/2083Start of certificate salesFebruary 1, 2027, via a central joint platformEuropean CommissionFirst declaration and payment by September 30, 2027 (for 2026 imports)European Commission
What importers should check now:
For importing companies, the focus is shifting from reporting to data quality and financial planning. What matters most is no longer whether reports are submitted, but rather how reliable the embedded emissions data is for each supplier and product—because that is precisely what determines the number of allowances to be purchased and, consequently, a significant cost factor.
In practice, the real work rarely involves the CBAM form itself, but rather the supply chain: Those who know the CO₂ intensity of their intermediate products pay for actual emissions; those who do not know it pay based on conservative default values. The CBAM thus links procurement directly to suppliers’ CO₂ data.
From a consulting perspective: The postponement of the certificate sale until 2027 is often misunderstood as a green light. It is not. The costs for 2026 are already accruing; only the payment date has been postponed. Companies that treat 2026 as a “buffer year” risk facing double pressure in 2027—from retroactive permit purchases and ongoing coverage requirements.
The second underestimated issue is data quality in the supply chain. In our projects, we regularly see that determining embedded emissions takes significantly longer than the formal CBAM registration—especially when suppliers outside the EU have not yet provided reliable product CO₂ figures. Addressing this early on not only reduces the administrative burden but also lowers the actual volume of allowances required.
Our recommendation: Quantify and set aside provisions for the CBAM liability for 2026 now; at the same time, begin collecting emissions data from the relevant suppliers; and use the final text of the Delegated Regulation as a trigger for procurement planning.
The delayed launch of the CBAM doesn’t make it any cheaper—it just makes it easier to plan for. The crucial next steps for importers are: quantifying and setting aside provisions for the allowance burden due in 2026, ensuring the reliability of suppliers’ emissions data, and using the final text of the Delegated Regulation as the starting signal for procurement. Those who thoroughly verify the 50-metric-ton threshold and use primary data instead of default values save twice—in effort and in allowances.
CBAM 2026/2027: Quantify your allowance burden and establish a data foundation in your supply chain. A brief initial consultation will clarify your 50-metric-ton assessment, the calculation of embedded emissions, and the most sensible first step for your company. Schedule an initial consultation.

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