Senseible

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

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

A buyer's 2026 imports by quarter, example numbers

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.

Sources: European Commission, CBAM Questions and Answers, last updated 15 October 2026, questions 3.1, 3.3, 3.5, 3.6, 3.7 and 5.20

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.