EU CBAM 2026: What Exporters’ EU Buyers Will Pay and When

With EU CBAM 2026, the Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. After a three-year transitional period of reporting-only obligations, it now carries real financial consequences for businesses exporting steel, aluminium, cement, fertilisers, electricity or hydrogen into the European Union. The European Commission published the first quarterly CBAM certificate price on 7 April 2026, EUR 75.36 per tonne of CO2 for Q1 2026 imports, followed by EUR 75.28 for Q2 and EUR 82.32 for Q3.

Exporters in India, China, Turkey and Vietnam supplying EU markets now face a carbon cost embedded in every tonne of covered goods they ship to Europe. This guide explains what CBAM requires, how to calculate your exposure, which countries face the highest costs, and what changes in your export business model when carbon pricing becomes a structural feature of your EU landed cost.

The short version. The EU importer, or its indirect customs representative, buys and surrenders CBAM certificates, but the exporter’s emissions data decides the bill. Importers above 50 tonnes a year need authorised CBAM declarant status. Certificates go on sale on 1 February 2027, and the first annual declaration and surrender for 2026 imports are due by 30 September 2027. The cost is not simply 2.5% of your emissions. It is your embedded emissions minus a benchmark-based free allocation adjustment, so high-carbon producers pay far more than the headline suggests.

Carra Globe provides importer of record, exporter of record, delivered duty paid and freight forwarding services, so we have a commercial interest in your answer. What follows is written to be usable whether or not you ever speak to us.

What EU CBAM 2026 actually requires

CBAM is a carbon pricing mechanism applied at the EU border. Its purpose is to prevent carbon leakage, where EU manufacturers lose ground to producers in countries without comparable carbon pricing. Importers bringing covered goods into the EU must buy and surrender CBAM certificates representing the embedded emissions in those goods. The certificate price follows EU Emissions Trading System (ETS) auction prices, so imported goods face a carbon cost comparable to goods made inside the EU by ETS-regulated producers.

The key obligations are set out below.

• Who is responsible. The EU importer or its indirect customs representative. The non-EU exporter is not directly liable to the EU under CBAM, but its emissions data and evidence of any carbon price paid directly shape the cost its EU buyer faces. Exporters with high embedded emissions or no evidenced carbon price make their EU customers more expensive to supply, creating competitive pressure across the supply chain.
• What goods are covered. Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. A Commission proposal of 16 December 2025 would extend the scope to around 180 steel and aluminium intensive downstream products from 1 January 2028. It has not been enacted, so exporters in adjacent product categories should monitor its progress.
• 50-tonne threshold. Importers bringing in 50 tonnes or less of covered iron and steel, aluminium, fertiliser and cement goods in a calendar year are exempt from CBAM obligations. Hydrogen and electricity are outside the exemption. The threshold counts the covered goods imported over the calendar year, not each shipment, and once it is exceeded the whole year’s imports fall under the CBAM rules. Whether an indirect customs representative needs authorisation depends on whether it is required to act, or has agreed to act, as the CBAM declarant.
• Certificate price. For 2026 imports, the Commission publishes a quarterly price based on the weighted average of EU ETS auction clearing prices. The published prices are EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3, with Q4 due on 4 January 2027. Weekly prices start in 2027.
• Phase-in. CBAM rises as free EU ETS allowances are withdrawn. In law the CBAM factor is the share of free allocation still given, 97.5% in 2026, falling to 95% in 2027, 90% in 2028 and zero in 2034. The commonly quoted 2.5% is the share withdrawn, and it does not mean you pay 2.5% of your emissions, as the next section shows.
• Deadlines. Certificates go on sale on 1 February 2027. The first annual declaration, covering all CBAM goods imported during 2026, and the surrender of certificates for those imports are both due by 30 September 2027. From 2027, declarants must also hold certificates covering at least 50% of embedded emissions at each quarter end.
• Authorised CBAM declarant status. Importers above the 50-tonne threshold need authorisation from the competent authority in their member state. Those who applied by 31 March 2026 could keep importing while their application was considered. The official guidance is published by the European Commission, Taxation and Customs Union.

How to calculate your carbon cost exposure

The CBAM cost is not your emissions multiplied by 2.5%. The number of certificates is worked out from the goods’ embedded emissions, the free allocation adjustment that applies to them, and any qualifying deduction for a carbon price effectively paid abroad. The adjustment is built on the EU benchmark for the product rather than the producer’s own emissions, so producers above the benchmark carry most of the gap.

A simplified way to picture it, not the legal formula, is shown below. The detailed adjustment method, including how benchmarks, production routes and actual or default data interact, is set out in Implementing Regulation (EU) 2025/2620, and any carbon price deduction follows its own rules.

Certificates ≈ Embedded emissions − (Tonnes × CBAM benchmark × CBAM factor), before any carbon price deduction. Cost = Certificates × Certificate price for the quarter of import.

Here is an illustration, using the Q1 2026 price of EUR 75.36 and a hypothetical benchmark of 1.5 tCO2e per tonne. Real benchmarks vary by product and production route. The example leaves out any carbon price deduction and verification detail, so a real shipment needs the full calculation and supporting data.

• 500 tonnes of steel at 2.0 tCO2e per tonne. Embedded emissions are 1,000 tCO2e. The adjustment is 500 x 1.5 x 97.5% = 731.25, leaving 268.75 certificates, or about EUR 20,253 for Q1 2026.
• The same shipment in 2034, when the CBAM factor reaches zero under the schedule now in force. The full 1,000 tCO2e would be payable, about EUR 75,360 at the same price, or roughly 3.7 times the 2026 cost. Prices, benchmarks and the phase-out itself may change before then, as the EU ETS review continues.
• Why the 2.5% shortcut misleads. Multiplying 1,000 tCO2e by EUR 75.36 and 2.5% gives EUR 1,884, about a tenth of the illustrated cost. The shortcut only works if a producer’s emissions exactly match the benchmark.
• Carbon price deduction. A carbon price effectively paid in a third country, net of any rebate or compensation, can reduce the obligation if the declarant holds the evidence the rules require. Since the 2025 amendments, this can be a price paid in any third country, not only the country of origin. The existence of a carbon market alone earns nothing.

The critical variable for non-EU exporters is whether their buyer uses verified actual emissions or EU default values. Default values are set by country and product, based on average emission intensity and then marked up by 10% in 2026, 20% in 2027 and 30% from 2028, with fertilisers treated differently. Exporters who rely on defaults generally impose higher CBAM costs on their EU buyers than exporters whose actual emissions are lower and verified. Importers may also choose defaults even where actual data exist.

Which countries face the highest carbon border costs in 2026

CBAM costs vary by country of origin because they reflect the carbon intensity of production and any carbon price paid. The figures below are Fastmarkets estimates published on 30 September 2026, for hot-rolled coil made through the blast furnace and basic oxygen furnace route at Commission default values. They are not a rate for every steel product, route, producer or shipment from those countries.

• India. Among the highest default costs, which Fastmarkets put at about EUR 254 per tonne for Q1 and EUR 278 per tonne for Q3 2026, for blast furnace hot-rolled coil at default values. India’s steel sector relies heavily on coal-based blast furnace production with limited domestic carbon pricing. Exporters that invest in verified emissions reporting and lower-carbon production can reduce this exposure materially, and our guide to the India-EU free trade agreement covers the wider trade picture.
• Turkey. About EUR 101 per tonne for Q1 and EUR 110 per tonne for Q3 2026 on the same Fastmarkets basis. Turkey is one of the EU’s largest steel suppliers. Its Climate Law of July 2025 provides for a national ETS, but EU buyers should not assume Turkish carbon costs will cut their bill. A deduction needs a qualifying price actually paid, net of rebates, and backed by the required evidence.
• Vietnam. Vietnamese steel also faces default-value costs where verified data is missing. We have not found an official or current per-tonne figure, so check the latest default values for your product.
• China. China extended its national carbon market to steel, cement and aluminium in March 2025, with allowances in these sectors largely allocated free at this stage. What counts is the carbon price a specific producer has effectively paid and can evidence to the EU declarant, which may be small.
• UK. Carbon costs paid under the UK ETS may reduce an EU buyer’s CBAM obligation, but the claim belongs to the authorised CBAM declarant, which needs evidence of the price effectively paid. At their May 2025 summit, the UK and EU agreed to work towards linking their emissions trading systems, which would allow mutual exemptions from each other’s CBAM.

How carbon border rules are rewriting export business models

CBAM does not apply to the non-EU exporter directly, and the EU importer pays the certificate cost. But the commercial reality is that the cost flows back through the supply chain. An EU steel buyer importing Indian steel at around EUR 254 to EUR 278 per tonne in carbon costs at default values has a structural cost disadvantage against a buyer sourcing from a lower-carbon origin or from within the EU. That buyer either absorbs the cost, passes it to its customer or changes supplier.

Emissions verification is now a commercial competitive advantage

Exporters whose actual emissions are lower than the defaults gain by verifying them. Defaults reflect a country’s average emission intensity plus a mark-up, so a cleaner producer relying on them pays for its neighbours. An Indian steel producer using direct reduced iron technology with natural gas may have actual emissions well below the country default. If that producer can provide accredited third-party verification, its EU buyers pay substantially less in CBAM certificates than competitors sourcing from producers who rely on defaults.

Emissions verification is therefore not just a compliance exercise. It is a pricing tool that directly affects the competitiveness of every tonne sold into the EU market. Exporters who treat it as optional overhead are ceding margin to competitors who treat it as commercial infrastructure.

Carbon pricing in the exporting country reduces EU buyer costs

A carbon price actually paid abroad reduces the certificates the EU importer must surrender. This creates a direct commercial incentive in countries considering domestic carbon pricing. If a future Turkish ETS charged a producer EUR 30 per tonne of CO2 with no rebate, and the producer could evidence it, its EU buyer’s CBAM cost could fall by the equivalent amount. An exporter operating in a country with no carbon pricing provides no such offset. As CBAM scales toward full implementation in 2034, the commercial value of a domestic carbon price for exporters targeting the EU market increases.

Trade route diversion and product category shifts

CBAM creates a structural incentive to route lower-carbon products toward the EU and higher-carbon products toward non-CBAM markets. EU buyers are prioritising suppliers with lower embedded emissions and verified data. Producers in high-carbon-intensity countries are exploring non-EU export routes for their most carbon-intensive output while investing in cleaner production for EU-bound supply. Trade agreements such as the EU-Mercosur agreement do not remove CBAM, so the carbon cost sits on top of any tariff preference.

The proposed downstream extension would take CBAM beyond primary materials into manufactured components and finished goods. The Council agreed its position on 12 June 2026 (about 200 products) and the Parliament adopted its own on 15 September 2026 (around 457 product types). The file has gone back for negotiation between the institutions. Technical talks began on 28 September, and the first political trilogue is scheduled for 20 October 2026, as reported on 7 October. The proposal also adds anti-circumvention measures, and none of it is law yet.

Exporters of downstream products with significant steel or aluminium content should monitor it closely. If enacted, it would bring a much broader range of manufacturers into the framework.

The UK CBAM launches in 2027

The United Kingdom’s own CBAM starts on 1 January 2027. It covers aluminium, cement, fertiliser, hydrogen, and iron and steel. Glass and ceramics, proposed in 2023, are not in scope from 2027, and unlike the EU scheme it does not cover electricity. It also works differently, as a tax paid to HMRC by the importer rather than a system of certificates. Exporters supplying both markets will face parallel obligations. EU emissions data may help with UK reporting, but scope, accounting rules and deadlines need checking separately.

What CBAM means for your import and IOR structure

CBAM does not change customs duty or VAT obligations. It adds a carbon cost layer on top of existing import charges, as our guide to import VAT and the importer of record explains for the tax side. For businesses using an importer of record for EU market entry, who must be an authorised CBAM declarant depends on who is the importer, where it is established, whether an indirect customs representative is used and how the threshold applies.

A broker, forwarder or IOR does not become the declarant just by handling a shipment, so identify the legal role first. If the role is new to you, start with what an importer of record does.

CBAM compliance sits alongside standard EU customs clearance but runs through a separate registry. Importers and indirect representatives acting for CBAM goods in Germany, the Netherlands, France and other EU entry points need CBAM authorisation in addition to their customs registration and EORI number. Businesses importing steel, aluminium, cement or fertilisers through a third party should confirm now that it holds authorised CBAM declarant status, well before the 30 September 2027 declaration deadline. The customs code itself is also changing, covered in our guide to the 2027 Union Customs Code changes.

How Carra Globe supports CBAM compliance

Carra Globe provides importer of record and global trade compliance services for businesses importing CBAM-covered goods into the EU. Our EU-registered entities in Germany, the Netherlands, France, Spain and other member states are positioned to support CBAM declarant registration and ongoing compliance. For goods leaving the EU, our exporter of record service covers the export side.

Our delivered duty paid service for CBAM-covered goods includes CBAM cost modelling as part of the landed cost calculation. Buyers see the carbon certificate exposure before committing to purchase, and our guide on how to compare DDP quotes shows what to check in any quote. Our freight forwarding service coordinates CBAM shipment documents, including embedded emissions data from suppliers and the chain of custody records needed for verification.

Carra Globe works through importer-side registrations and local importing structures appropriate to the goods and destinations it accepts, its own in some markets and established local structures in others. Approvals falling outside the available structure are flagged before a delivery date is agreed. Send your product list, origins and annual EU volumes to info@carraglobe.com and we will tell you where the CBAM exposure sits.

Frequently asked questions

What is the CBAM certificate price in 2026?

The Commission set EUR 75.36 per tonne of CO2 for Q1 2026, EUR 75.28 for Q2 and EUR 82.32 for Q3, each a weighted average of EU ETS auction prices. Weekly pricing starts in 2027.

Who pays CBAM in 2026, the EU importer or the non-EU exporter?

The EU importer or its indirect customs representative buys and surrenders certificates. The exporter pays nothing to the EU, but its emissions data and any carbon price paid decide the buyer’s cost.

When must CBAM certificates be purchased and surrendered?

Certificates go on sale on 1 February 2027. The first annual declaration and the surrender of certificates for 2026 imports are both due by 30 September 2027.

What happens if an exporter cannot provide verified emissions data?

The importer uses the Commission’s default values, based on average emission intensity by country and product plus a mark-up of 10% in 2026. That usually costs more than verified actual emissions.

Is EU CBAM 2026 only for large exporters?

Importers bringing in 50 tonnes or less of CBAM goods a year are exempt, except for hydrogen and electricity. The threshold is the importer’s annual total, so growing volumes can bring a customer into scope.

How does CBAM interact with standard EU customs clearance and IOR?

CBAM runs alongside customs clearance through a separate registry, and duty and VAT are unchanged. Which party needs declarant authorisation depends on its legal role as importer or indirect representative.

Adjacent ground: the EU digital product passport and importer liability, the EU Battery Regulation for importers and an EU distribution hub in the Netherlands.

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Sources and verification

Sources checked on 14 October 2026.

• CBAM overview. European Commission, CBAM, definitive regime from 1 January 2026.
• Certificate prices. European Commission, price of CBAM certificates, EUR 75.36 (Q1, 7 April 2026), EUR 75.28 (Q2, 6 July 2026), EUR 82.32 (Q3, 5 October 2026).
• Legal text. Regulation (EU) 2023/956, consolidated, Article 6 (declaration by 30 September, first in 2027), Article 20 (sales from 1 February 2027), Article 22 (surrender and 50% quarterly holding), Article 31 (free allocation adjustment), Article 9 (carbon price paid). Regulation (EU) 2025/2083, the simplification amendment.
• Legislation and guidance. European Commission, CBAM legislation and guidance, including Implementing Regulations (EU) 2025/2620 (benchmarks) and 2025/2621 (default values).
• Threshold and authorisation dates. Malta Climate Action Authority, CBAM, 50 tonnes, applications by 31 March 2026.
• Downstream extension. European Parliamentary Research Service, September 2026.
• UK CBAM. HM Government, CBAM factsheet.
• Country cost estimates. Fastmarkets, “CBAM Certificate Index rises to EUR 82.32/tCO2e in third quarter”, 30 September 2026, India and Turkey figures for blast furnace hot-rolled coil at default values. A commercial source, cited by name under the official-sources link rule.
• Downstream status. European Parliament position adopted 15 September 2026, with trilogue timing as reported by Mayer Brown, 7 October 2026.
• UK CBAM design. HM Government, CBAM policy paper, a tax paid to HMRC.

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Disclaimer: This guide is for informational purposes only and does not constitute legal, tax or customs advice. CBAM rules, values and prices change, and this guide reflects the position as at 14 October 2026.