On 7 April 2026, the Commission published the first quarterly CBAM price at EUR 75.36 per certificate for the first quarter of 2026. The prices for the remaining quarters will be released on 6 July 2026, 5 October 2026, and 4 January 2027, respectively. Each quarterly price will apply to the sale of CBAM certificates for emissions from CBAM goods imported into the Union during that quarter. From 2027 onwards, the price will be published weekly.

How Many Certificates Must Be Surrendered?

The number of CBAM certificates to surrender is determined by the amount of imported CBAM goods and their specific embedded emissions. This amount is reduced by the emissions covered by EU ETS free allocation, and—where relevant—further reduced by emissions already covered by a carbon price that has been effectively paid in the country of origin or a third country. One CBAM certificate equals one tonne of CO₂ equivalent.

How and When Are Certificates Purchased?

There is no obligation to hold CBAM certificates during 2026. As certificate sales on the common central platform begin only from February 2027, there is no legal obligation to hold certificates during 2026.

From 1 February 2027, Member States will sell CBAM certificates to authorised CBAM declarants on a common central platform managed by the Commission. Certificates are sold at the applicable price, each has a unique identification number, and sale details are recorded daily in the CBAM Registry. Authorised CBAM declarants may purchase certificates at any time throughout the year.

The Quarterly Holding Obligation — From 2027

From 2027, authorised CBAM declarants must ensure that, by the end of each quarter, they hold CBAM certificates covering at least 50% of embedded emissions in all goods imported since the beginning of the calendar year. This is determined by either default values (without the mark-up) or by the number of certificates surrendered for the preceding year for the same goods by CN code and country of origin. The quarterly holding obligation takes account of the free allocation adjustment. This obligation is assessed at the end of each quarter: 31 March, 30 June, 30 September, and 31 December.

Annual Surrender and Key Deadlines The deadline for both the first CBAM declaration and the first certificate surrender is 30 September 2027, covering the year 2026. These two obligations must be met at the same time. After certificates are surrendered, any excess certificates may be repurchased at the original purchase price, provided a request is made by 31 October of the year of surrender. On 1 November 2027, any certificates purchased for 2026 embedded emissions that remain in accounts will be cancelled by the Commission without compensation. If the required certificates are not surrendered, a significant penalty applies. The penalty for uncompensated emissions is EUR 100 per tonne, indexed to the European consumer price index. Importantly, paying the penalty does not release the declarant from the obligation to surrender the outstanding certificates.

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Photo of Vassilis Akritidis Vassilis Akritidis

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive compliance and proper corporate governance are essential for success. Vassilis organizes compliance training programs for executives to ensure smooth and cost-effective navigation through the complex web of EU and World Trade Organization regulations.

Vassilis has been practicing EU and international trade law in Brussels since 1991. He qualified in Athens as a maritime lawyer and then pursued graduate studies in European law at the Institute of European Studies in Brussels. An internship at the State Aid Directorate-General for Competition convinced Vassilis that EU and supranational law are hugely interesting. He started as an EU competition and public procurement lawyer and over the years focused increasingly on international trade and WTO law. Vassilis is regularly quoted by renowned legal directories as an expert in these fields.

Vassilis helps his clients win trade investigations, achieve and improve market access, maximize trade benefits, and be trade-compliant wherever they operate. He advises and represents private clients, professional associations, and governments in trade defense investigations (anti-dumping, anti-subsidy, safeguards), customs investigations and litigation, trade sanctions/export controls, and EU anti-fraud investigations led by the European Anti-Fraud Office and the European Public Prosecutor’s Office. Vassilis also advises on EU State aid and EU internal market and public procurement.

Vassilis has worked for clients active in the steel, chemicals, high-tech, transport, defense and aerospace, automotive, and agriculture/food sectors. He represents clients before the EC and other non-EU trade defense authorities.

Should things get contentious, Vassilis is an experienced litigator, representing parties before EU courts in Luxembourg as well as national customs and administrative tribunals.

Vassilis works with his colleagues at Crowell Global Advisors, our global government relations, public policy, and public affairs affiliate, in matters involving EU public policy and lobbying.

Photo of Oleksii Yuzko Oleksii Yuzko

Oleksii Yuzko is a jurist with Crowell & Moring’s International Trade Group in Brussels, where he focuses on a wide range of international trade issues. His expertise includes trade remedies investigations, such as anti-subsidy and anti-dumping cases, along with customs-related matters.

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Oleksii Yuzko is a jurist with Crowell & Moring’s International Trade Group in Brussels, where he focuses on a wide range of international trade issues. His expertise includes trade remedies investigations, such as anti-subsidy and anti-dumping cases, along with customs-related matters.

Oleksii assists a diverse group of clients, including domestic industries, exporters, importers and users at all stages of trade remedies investigations before the European Commission, UK’s Trade Remedies Authority and the U.S. Department of Commerce. His work particularly focuses on the chemicals, timber, aluminum, and steel sectors.

Prior to joining Crowell, Oleksii developed his expertise in the non-profit sector and at an intergovernmental organization, where he focused on human rights and the rule of law.