EU CBAM Certificate Pricing Interface — EU ETS Price Linkage and Country-of-Origin Carbon Price Deduction
ENFORCEMENT TIMELINE
Applies from the start of certificate sales in February 2027 (2026 imports use the 2026 EU ETS quarterly average price)
Overview
This card focuses on the specific operational practice for the pricing methodology of CBAM certificates (Regulation (EU) 2023/956, simplification amending Regulation (EU) 2025/2083), and for the procedure by which a carbon price already paid in the country of origin of CBAM goods is deducted.
The price of certificates purchased in 2027 (corresponding to 2026 imports) is based on the average EU ETS allowance price of the quarter in which the goods were imported (Article 21(1a)). Certificates purchased thereafter are priced based on the weekly average closing price of EU ETS auctions, with the European Commission calculating and publishing the price on a regular basis. Where a carbon price (such as a carbon tax or emissions trading system price) has already been paid in the country producing CBAM goods, that amount can be deducted from the number of certificates to be surrendered under the CBAM declaration where actual emissions are used (Article 9(1)); where default values are used, a deduction is possible only by reference to yearly default carbon prices (Article 9(4)). From 2027, the European Commission will also be able to determine and publish default carbon price levels and their calculation methodology in the registry for third countries that have their own carbon pricing systems.
Enforcement Timeline
During 2026: The EU ETS certificate's quarterly average price begins to be recorded as the basis for pricing certificates purchased in 2027.
February 1, 2027: CBAM certificate sales begin. The first price applied is based on the 2026 quarterly average.
From 2027 onward: The certificate pricing methodology shifts to a basis of the weekly average closing price of EU ETS auctions. The European Commission is also expected to begin determining and publishing default carbon prices for third countries.
Business Impact
Importers need to continuously monitor the trajectory of EU ETS certificate prices to forecast their CBAM certificate procurement costs. Once certificate pricing shifts to a weekly average basis in particular, shorter-term price fluctuations will be reflected in procurement costs, making risk management through measures such as spreading out procurement timing practically important.
For imported goods on which a carbon price has already been paid in the country of origin, businesses need to build a system for collecting from suppliers the payment evidence (such as tax payment certificates or proof of participation in an emissions trading system) required for the deduction procedure. Once the European Commission's mechanism for publishing default third-country carbon prices becomes operational, a certain level of deduction may become available even where individual evidence collection is difficult — though the actual start date and the countries covered remain to be announced.