Importers of steel, aluminum and other carbon-intensive goods can finish 2026 without buying a single border carbon certificate and still owe a sizable bill for what they brought in this year. The payment is delayed. The exposure is not, and the gap between the two is where 2027 budgets can go wrong.
The European Union's Carbon Border Adjustment Mechanism (CBAM) charges EU importers for the emissions embedded in iron and steel, aluminum, cement, fertilizers, electricity and hydrogen. Its definitive regime took effect January 1, 2026. Under the schedule described by Germany's national CBAM authority, DEHSt, declarants buy certificates for this year's imports retrospectively, starting in February 2027, and must surrender them by September 30, 2027. For a procurement team, the job this quarter is turning customs records and supplier emissions data into a figure finance can defend.
CBAM Certificate Prices for 2026 Imports Follow the Quarter of Entry
The European Commission prices each 2026 certificate at the weighted average of EU Emissions Trading System (EU ETS) auction clearing prices for a given quarter. According to the Commission's certificate price page, each quarterly figure applies to emissions in goods imported during that quarter. The first-quarter price came in at $85.57 (€75.36), published April 7. The second quarter followed at $85.48 (€75.28) on July 6. A third-quarter figure covering shipments cleared through September 30 is due in the first calendar week of October.
Buying later does not change the rate. An importer cannot hold off until 2027 and apply a cheaper carbon price to goods that arrived this spring. What remains open is the number of certificates owed, and that number depends on records procurement already controls. Each shipment's customs code, quantity, origin and producing installation needs to stay attached to its import quarter. A supplier's annual emissions average strips out the timing that sets the price.
Scope deserves a check before any cost is assigned. The 2025 simplification package, summarized by the International Carbon Action Partnership (ICAP), exempts importers bringing in 50 metric tons or less a year of covered goods, counted cumulatively. Electricity and hydrogen sit outside that exemption. The Commission estimates the threshold removes about 90% of importers from the system while keeping 99% of embedded emissions covered, so occasional buyers may have nothing to budget while large ones carry nearly all of it.
Free Allocation and Foreign Carbon Prices Shrink the Certificate Count
Multiplying gross embedded emissions by a carbon price overstates the bill. The certificates owed are reduced to reflect the free EU ETS allowances that European producers of comparable goods still receive. A carbon price already paid in the country of production can lower the count further. The Commission's ten guidance documents released August 14 walk through the free allocation calculation and monitoring expectations, with worked examples for each sector. They also direct importers to use actual emissions values for 2026 goods.
The foreign-price deduction is less settled. A draft implementing act, reported by Fastmarkets in May, sets out which carbon taxes and trading systems count and caps international carbon credits at 10% of an installation's emissions. Once adopted it would apply back to January 1, 2026. Until the final text appears, a budget estimate should show the deduction as a range with its assumptions written down.
These adjustments pull supplier selection into the budget discussion. Two mills quoting an identical price per ton can leave an importer with very different certificate counts once verified installation data is on the table. Procurement teams that ask for usable emissions evidence alongside the next quote gain a cleaner comparison, and they build data obligations that hold up inside supply agreements before a dispute forces the issue.
Cash Needs in 2027 Arrive in Two Layers
Surrendering certificates for 2026 imports is only the first call on cash. Once sales open, declarants must also hold certificates equal to at least 50% of the embedded emissions in goods imported since the start of the calendar year, checked at each quarter-end. A company that keeps importing through 2027 therefore funds last year's obligation and a rolling balance for the current year at the same time.
Treasury will get a more useful picture if the estimate separates those layers. The historical obligation for 2026 goods sits on one line. Current-year holdings sit on another, with the open variables named beside them. Those variables include supplier data quality, the unpublished third- and fourth-quarter prices, and whether deductions survive verification. How CBAM is recognized in the accounts is a separate judgment under the company's reporting framework. A missing cash payment in 2026 is not a sound reason to leave it out of management budgets.
Contract language needs work too. A clause that simply passes carbon costs through, with no agreed method for calculating them, invites an argument after delivery. Responsibility for supplying data, correcting it and bearing a defined adjustment belongs in writing. Supply agreements are already being redrafted to divide cost and liability more explicitly, and CBAM terms fit naturally into that work.
Producers Outside Europe Control the Emissions Data Behind the Bill
Suppliers outside Europe have a stake too. American mills, smelters and fertilizer plants selling into Europe control the installation-level data that decides how many certificates their customers buy. The Commission issued a separate roadmap for non-EU operators in its August package. A producer able to hand over verified figures quickly gives its European buyers a lower, more predictable number. As border carbon rules reprice cross-border trade, that responsiveness becomes part of what an exporter is selling.
Several dates will sharpen the estimate over the coming months. The third-quarter certificate price arrives next week and the fourth-quarter price in early January, completing the rate card for 2026 imports. The final foreign-price deduction rules will show how much credit supplier-country carbon taxes earn. The central purchasing platform opens in February, and the first quarter-end holding test follows on March 31, 2027. The deduction rules are the least predictable of these, and for importers buying from countries with domestic carbon pricing, they may move the estimate most.
