Can an EU importer sell back unused CBAM certificates, and what happens to them after a year?
Partly. An authorised CBAM declarant can ask the Commission to repurchase certificates left over after the annual surrender, within a cap and a deadline set in Article 23. Certificates that are neither surrendered nor repurchased in time are cancelled under Article 24. They cannot be sold to other importers.
Repurchase under Article 23
After the annual declaration and surrender, the declarant can request that the Commission buy back excess certificates still in its registry account. The Regulation sets the repurchase price and caps how many certificates can be repurchased, so buying well above need can mean money lost. Check the current consolidated text of Article 23 for the price and the cap.
Cancellation under Article 24
Certificates still in the account after the surrender and repurchase window are cancelled by the Commission. Check the current consolidated text of Article 24 for which certificates are cancelled, when, and whether any payment applies.
No secondary market
CBAM certificates are not EU ETS allowances. They are sold by a central platform to authorised declarants only, and cannot be traded or transferred between declarants. The only exits are surrender, repurchase or cancellation.
Dates after the 2025 simplification
Regulation (EU) 2025/2083 moved the annual declaration and surrender to 30 September of the following year and started certificate sales in February 2027 for 2026 imports. The repurchase and cancellation timing moved with it. Take the exact dates from the consolidated CBAM Regulation before planning purchases.
Worked example: how much might be sold back (illustrative)
- Certificates bought: 900 (illustrative)
- Certificates surrendered for the declaration: 700
- Excess: 900 minus 700 = 200
- Compare the 200 with the repurchase cap in the current Article 23: only certificates within the cap can be repurchased
Anything above the cap and not surrendered faces cancellation under Article 24.
What Senseible does here
Senseible does not buy, hold or sell CBAM certificates. Its CBAM cost calculator estimates certificate cost from 2026 to 2034, which helps an importer size purchases.
Sources: Regulation (EU) 2023/956, consolidated text, Articles 23 and 24, Regulation (EU) 2025/2083 (CBAM simplification), European Commission: price of CBAM certificates
Last reviewed 2026-10-15. Repurchase limits and dates were changed by Regulation (EU) 2025/2083 and may change again; confirm Articles 23 and 24 against the consolidated CBAM Regulation.