The EU’s Carbon Border Adjustment Mechanism (CBAM) is now in its definitive phase. Until the end of 2025, importers focused on emissions reporting. From January 1, 2026, imports create CBAM certificate cost exposure and reporting shifts to an annual declaration with verification requirements.

CBAM certificates sit at the center of this system. They represent the carbon cost linked to the embedded emissions in your imported goods and determine how many certificates you will need to surrender for 2026 imports.

This article explains what CBAM certificates are, how the certificate process works and what mid-market importers should do in 2026 to stay compliant. It covers the practical steps that matter most – getting supplier emissions data in the right format, building a verification-ready workflow and forecasting certificate exposure over time.

What is a CBAM certificate?

A CBAM certificate is the unit importers will need to purchase and surrender to comply with the EU’s CBAM regulation. Each certificate represents one tonne of CO₂-equivalent emissions embedded in the imported goods.

From 2026, importers of carbon-intensive products such as cement, steel, aluminium, fertilizers, electricity, and hydrogen will need to match the emissions of their goods with CBAM certificates. 

Plugging carbon leakage

The goal is to level the playing field between EU producers who already pay for their emissions under the EU Emissions Trading System (EU ETS) and foreign producers who don’t face the same carbon costs. 

Without this adjustment, there’s a very real risk of carbon leakage, where companies move production to countries with weaker climate regulations, undermining the EU’s climate efforts. 

In fact, according to European Parliament data, over 20% of the EU’s total CO₂ emissions are tied to goods and services produced outside the EU but consumed within it.

A carbon payment mechanism

The price of CBAM certificates will reflect the weekly average price of EU ETS allowances. This means the financial impact on importers can vary over time and will require ongoing tracking and forecasting.

For example, as of December 2025, the average price was approximately €83.90 per tonne of CO₂e. If you were importing goods with 1,000 tonnes of embedded CO₂ emissions, your CBAM certificate cost would be around €83,900 at that price point.

Think of CBAM certificates as a carbon payment mechanism. While the previous transitional phase focused only on reporting, now the definitive phase will bring real financial and administrative obligations.

Understanding how certificates work is essential for budgeting, supplier engagement, and compliance planning.

When will you need to buy CBAM certificates?

The definitive phase of CBAM commenced on 1 January 2026. From this date, importers of covered goods into the EU are required to monitor and calculate the embedded emissions of their products.

Key dates:

• 1 January 2026: Start of the definitive phase; begin monitoring and calculating embedded emissions.
• 30 September 2027: Deadline for submitting the 2026 CBAM declaration and surrendering certificates, as per current regulation.
  

Businesses need work with suppliers to access emissions data and put systems in place to calculate and track embedded carbon accurately.

The takeaway? Failure to be CBAM compliance will come with a real cost, and businesses that start preparing now will be better positioned to manage that cost effectively.

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How are CBAM certificate prices determined?

CBAM certificate prices are not fixed. Instead, they’re tied to the weekly average price of EU ETS allowances. That means the cost of compliance will rise or fall with the carbon market.

Importers will need to monitor carbon prices regularly to forecast costs accurately and avoid budgeting surprises. The EU publishes the average ETS price each week, which sets the price for CBAM certificates during that period.

Non-EU carbon system examples

In some cases, importers may be able to reduce their CBAM liability if a carbon price was already paid in the country of origin. The paid amount can be deducted from the number of CBAM certificates required. But this only applies to countries with recognized carbon pricing systems. For example:

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Accepted:

• Switzerland ETS (formally linked to the EU ETS)
• Norway, Iceland, and Liechtenstein (non-EU countries that participate directly in the EU ETS through the European Economic Area agreement)
  
  

Not accepted:

• UK ETS – plans to introduce its own CBAM by 2027)
• China’s national ETS – currently covers only the power sector and does not apply to industrial exports, making it ineligible for CBAM deductions
• India – lacks a nationwide carbon pricing mechanism that meets CBAM criteria
• Turkey – in the process of establishing an ETS, but it is not yet operational or linked to the EU ETS

How to get and manage CBAM certificates

To purchase and use CBAM certificates, companies must first register as authorized CBAM declarants. 

The European Commission opened the CBAM declarant registry on March 31, 2025, giving companies a head start on the authorization process. Without this status, you won’t be able to access the CBAM Registry or complete your obligations under the mechanism.

The process works as follows:

1. Apply via your National Competent Authority (NCA)

Each EU Member State has its own NCA responsible for approving CBAM declarants. Submit your application as early as possible, as authorization is required to import CBAM-covered goods from 2026 onward.

2. Receive CBAM account and access to the CBAM Registry

Once authorized, companies will be issued a CBAM account in the EU-wide CBAM Registry: a central platform for purchasing, holding, and surrendering certificates.

3. Purchase certificates through the registry

You can buy CBAM certificates directly through the Registry, at the weekly price set by the EU based on the ETS average. Purchases are limited to what you need and must align with reported emissions.

4. Surrender certificates annually based on reported emissions

Importers must surrender CBAM certificates to cover the verified embedded emissions linked to the previous year’s imports. For 2026 imports, the first annual CBAM declaration and certificate surrender deadline is September 30, 2027, approved as a part of recent Omnibus changes.

During the year, importers also need to keep enough certificates in their CBAM Registry account. The CBAM rules require importers to hold certificates corresponding to at least 80 percent of the embedded emissions in covered imports made since the start of the calendar year (see Article 19).

Be aware that CBAM certificates are also non-tradable and non-transferable. This means they can’t be resold or shared across entities, unlike EU ETS allowances, and each importer is individually responsible for compliance.

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Forecasting your certificate liability

CBAM is now in its definitive phase and 2026 imports create certificate cost exposure. The best way to avoid budget surprises is to forecast certificate needs early using supplier-specific emissions data – not conservative defaults.

Start by estimating annual embedded emissions across your in-scope CN codes, then run a few EU ETS price scenarios to translate emissions into expected certificate costs. Keep supplier data collection on a regular cadence so you can spot gaps, improve data quality and update forecasts as volumes and suppliers change.

This approach helps in two ways. It gives finance a defensible budget baseline and it shows where supplier engagement or sourcing decisions can reduce long-term exposure as costs rise over time.

Next steps

With CBAM’s definitive phase now here, it is the time to shift from reporting to readiness.

Coolset helps mid-market importers collect supplier emissions data, validate it and forecast certificate exposure in one system. Get in touch if you want a clearer view of your 2026 position and what it means for cost and compliance.

Request a demo today to see how we can support your CBAM compliance.

FAQs - CBAM certificates

Here are some of the most common questions we hear about CBAM certificates with straightforward answers to help you prepare.

Who pays for CBAM?

Importers established in the EU are responsible for purchasing and surrendering CBAM certificates. Costs cannot be passed directly to suppliers outside the EU but may be factored into procurement strategies.

How are CBAM certificates different from EU ETS allowances?

CBAM certificates are non-tradable and non-transferable. They can only be used by the authorized declarant who purchased them. This differs from ETS allowances that can be traded across entities and markets.

What happens if I don’t surrender enough certificates?

If you fail to surrender enough CBAM certificates, you will receive a request from your competent authority to surrender the additional certificates within one month (see Article 19). Failure to report accurately and on time can lead to fines of €100 per excess tonne. Only authorized declarants can import. Unregistered companies may face stricter penalties or import restrictions.

Who is liable for emissions data accuracy?

The importing company is ultimately responsible for ensuring that emissions data reported under CBAM is accurate and verifiable even if it comes from a supplier. That’s why robust data collection and supplier engagement are essential.