How are Carbon Border Adjustment Mechanism (CBAM) certificates counted for goods imported in 2026 when certificate sales only start in February 2027?
The number to buy in 2027 starts from the emissions, in tonnes of carbon dioxide (CO2), in CBAM goods imported in each quarter of 2026, by calendar quarter of importation, before the reductions the Commission's Questions and Answers describe in 3.7. The Commission calculates four quarterly prices for 2026. Declarants buy from February 2027 and before 30 September 2027.
The special rule for 2026
Sales of certificates start in February 2027, so the Commission's Questions and Answers (Q&A) 3.3 give a special rule for 2026 imports above the annual threshold. The number of certificates the declarant buys in 2027 is calculated as the emissions, in tonnes of CO2, in CBAM goods imported into the European Union (EU) in each quarter in 2026. The split is by the calendar quarter of importation, and there is one price per quarter.
Dates in the Q&A
- Quarterly prices for 2026 were to be made public on 7 April 2026, 6 July 2026, 5 October 2026 and 4 January 2027, one for each quarter.
- Certificates are bought on the Commission's common central platform from February 2027 and before 30 September 2027.
- The annual declaration for 2026 and the surrender of certificates are both due by 30 September 2027.
- From 2027, declarants must also hold a minimum number of certificates every quarter: 50% of the emissions in goods imported since the start of the year, checked on 31 March, 30 June, 31 October and 31 December. The Q&A prints 31 October as the third date, which does not match a quarter end. Check Article 22(2) with your buyer's adviser.
Which quarter an import belongs to
Q&A 5.20 says what matters is when customs accepts the declaration that releases the goods for free circulation. A coil that clears on 30 December 2026 sits in the fourth quarter of 2026. The same coil cleared on 2 January 2027 sits in 2027, however early it was shipped.
What it means for a supplier
- Your buyer needs a figure per import, so tell it your 2026 verified or default position early.
- Ask which quarters carry the most of its volume. That is where its first purchase will be largest.
- Our reading: the tonnes of CO2 above are before the reductions described in Q&A 3.7: free allocation, and any carbon price paid in the country of origin.
A buyer's 2026 imports by quarter, example numbers
- Quarter 1: 120 tonnes of CO2
- Quarter 2: 80 tonnes
- Quarter 3: 100 tonnes
- Quarter 4: 60 tonnes
- Total: 120 + 80 + 100 + 60 = 360 tonnes of CO2, each quarter priced at its own quarterly price
Example numbers only, before free allocation and any carbon price paid in the country of origin.
What Senseible does here
Senseible does not file customs or CBAM declarations and does not decide origin or who the declarant is. It reads an Indian plant's fuel invoices and electricity bills into dated, fingerprinted installation records, the starting point for the figure your EU buyer asks for.
- How many certificates to hold each quarter
- How the certificate price is set
- Goods made in 2025, shipped in 2026
- Senseible for CBAM
Last reviewed 2026-11-05. Dates come from the Q&A as updated on 15 October 2026. Re-read questions 3.1 and 3.3 each quarter, check Article 22(2) for the quarterly holding dates (the Q&A prints 31 October), and check the Commission's price page for quarterly publication.