EU CBAM Certificates Rise to EUR 82.32 a Tonne for Q3, Up 9% Before Weekly Pricing in 2027

The Analysis

How does this shipment move? A coil of steel or a bundle of aluminium sections lands at Rotterdam or Antwerp, clears customs, goes into the yard and then into production. Nothing on the customs entry tells you what the carbon bill will be, because the carbon bill is not a customs duty. The Commission has set the CBAM certificate price for the third quarter of 2026 at EUR 82.32 per tonne of CO2 equivalent, against EUR 75.28 in the second quarter and EUR 75.36 in the first. It is the first material increase since the definitive period began, and the goods covered are iron and steel, aluminium, cement, fertiliser and hydrogen.

Check the tariff code before the duty treatment, and then notice that this one carries a third step which does not appear on the entry at all. CBAM sits beside customs rather than inside it. The obligation attaches to a CBAM declarant, runs through a national competent authority, and is discharged by surrendering certificates rather than by paying a line of duty at the port. That is why EUR 82.32 matters far more than it looks. It is not a rate applied to your customs value; it is a price applied to the tonnes of embedded emissions you declared. Which means the accuracy of your emissions figure has become, quite literally, a cash item.

The fourth-quarter price is due on 4 January 2027, and after that Brussels publishes weekly. That change is the part that will hurt the people who read the price move and stopped there. Quarterly pricing is something you can plan around. Weekly pricing turns the carbon line into a position you have to manage, with a timing decision sitting inside it. Between now and 4 January there is enough time to get the reporting side straight, and not a great deal more than that.

The three prices on the record are EUR 75.36 for the first quarter of 2026, EUR 75.28 for the second and EUR 82.32 for the third. That is an increase of EUR 7.04 on the second quarter, about 9 percent, and it is the first move of that size since the definitive period started. The number is not chosen by officials. It is calculated as a weighted average of EU emissions trading system auction clearing prices, which means it follows the carbon market rather than any policy target. The sectors covered are iron and steel, aluminium, cement, fertiliser and hydrogen. The fourth-quarter price is due on 4 January 2027 and publication then moves to weekly.

Why now? Because the mechanism is an index rather than a decision. Through the transitional phase importers filed reports and nobody bought certificates, so the published price was, in practical terms, an observation. In the definitive period the declaration converts embedded emissions into an obligation that has to be discharged by holding and surrendering certificates, and the index stops being informational and starts being payable. The third-quarter increase is therefore not really a CBAM story at all. It is a story about what allowance auction prices did during the quarter. That distinction is operational rather than academic: you cannot negotiate the certificate price and you cannot argue with it, but you can watch the underlying market it is derived from, and you can decide when you hold certificates against it.

Who this hits, and how hard, is a product of two numbers multiplied together: tonnes of embedded emissions and the certificate price. A cement importer and a steel importer with the same euro value of goods can face very different bills, because emissions intensity per euro of product differs sharply across the covered sectors. Inside steel, a mill running an electric arc furnace on scrap and a mill running an integrated route will not produce the same embedded emissions figure, and the certificate bill follows that gap. The consequence is that the exposure is not proportional to your import value; it is proportional to your carbon. Two buyers of what looks like the same product can be carrying quite different costs, and neither of them will see it on the customs entry.

When does it land? Several clocks are running and they are not the same clock. The price clock runs quarterly through 2026 and weekly from 2027. The declaration clock runs on its own cycle, with the annual report and the certificate surrender following it, which means the goods can be in your warehouse, already processed and already invoiced to your customer, before the carbon bill for them is settled. The customs clock is untouched by any of this. Put those together and you get the shape of the problem: the physical flow and the money flow are separated by months, so nothing in your logistics process will tell you whether your carbon position is correct.

Here is what the headlines leave out, and it is where the money goes. CBAM is not a customs procedure. It runs on a separate register, through a national competent authority, against an authorised declarant, and it is settled by surrendering certificates from an account. Your goods can be released, delivered, consumed and invoiced while the CBAM obligation for those same goods is still open. That decoupling produces the two accidents I expect to see. One is procedural: the importer assumes the broker has handled it, the broker mandate covers customs clearance, and nobody actually holds the declaration. The other is financial: the cash for certificates was never ring-fenced, so when the surrender date arrives the money is not sitting there, and the exposure lands on the declarant with penalties attached rather than on the goods.

There is something else nobody says out loud, and it is usually worth more than the price move. The figure you declare is often not your supplier's real figure. Embedded emissions have to rest on verified installation data. If your mill or smelter will not, or cannot, give you verified data, the rules push you towards default values, and default values are set on a conservative basis, typically at or above the poor end of the actual distribution for that product. A supplier that simply will not share data is therefore not a neutral choice; it is a decision to pay a higher carbon bill, and I will show below that the difference can be larger than the 9 percent price move everyone is quoting. Request verified installation-level data in the supply contract, with a deadline, before you spend another hour worrying about the certificate price.

The shift to weekly publication is the change that rewires how you work, and most coverage treats it as a footnote. Under quarterly pricing, a quarter of imports was priced off one published number, and you could build that into a quotation with a known validity. Under weekly pricing, the price that applies depends on when you acquire and surrender, not on when the vessel arrived. Carbon stops being a known cost you pass through and becomes an exposure with a timing decision inside it. Two consequences follow for commercial teams: a ninety-day price validity on a covered product is now a ninety-day open carbon position, and a customer insisting on fixed prices is asking you to carry that position at your own risk.

Run the shipment through the map I use, adapted for this one. Classification: the customs code for the goods is untouched by CBAM, but the CBAM goods category, and within it the specific CN lines and any listed precursors, is a separate classification exercise with its own list. Getting the customs code right tells you nothing about whether the product is a CBAM good or which emissions route applies to it. Declaration elements: this is where the money is. For each covered good you need the installation that produced it, the country of origin, the embedded emissions figure, whether that figure is actual verified data or a default value, and any carbon price already paid in the country of production that can be deducted. Examination: nobody opens the container for CBAM. The check is documentary, and it is a check of your emissions file rather than of your cargo. Payment: certificates, not duty, drawn from an account you have to keep funded. Release: unaffected, which is exactly why the obligation gets forgotten.

Decide deliberately who is the declarant. This depends on the port and on the member state, because the competent authority that registers you is national, but the decision itself is the same wherever you file. If your forwarder or customs agent is the declarant, the legal obligation sits with them and the economic burden sits with you, and that split is where trouble accumulates. Money and responsibility living in two organisations with no contractual service level around data is the classic failure mode. If you declare yourself, you need the authorised status, the account, and a named person who owns the filing calendar. Either way, put it in the contract with the agent: who files, by when, on whose data, and what happens when the data is late.

Put numbers on it with the assumptions explicit. Assume an EU importer brings in 2,000 tonnes a month of a covered steel product. Assume the embedded emissions declared for that product are 1.8 tonnes of CO2 equivalent per tonne of steel. That is my assumption for the arithmetic, not a published figure, and your real number depends on the installation and the production route. Monthly embedded emissions are then 3,600 tonnes. At the first-quarter price of EUR 75.36 the monthly certificate cost is about EUR 271,300. At the second-quarter price of EUR 75.28 it is about EUR 271,000. At the third-quarter price of EUR 82.32 it is about EUR 296,350. The quarter-on-quarter increase is about EUR 25,350 a month, roughly 9 percent, and annualised at the third-quarter price the bill is about EUR 3.56 million.

Now model the 2027 change on the same volume. Assume weekly prices move within a band of plus or minus 5 percent around the level you budgeted. On a monthly exposure of about EUR 296,000, a 5 percent swing is about EUR 14,800 a month, and over a year the difference between a favourable and an unfavourable run of weeks is roughly EUR 178,000 on this single product line. That arrives without any change in volume, grade or supplier, and on a steel programme it is not a rounding error. The arithmetic says what the mechanism says: from 2027 the carbon line carries a market risk, and market risk is handled by policy rather than by hoping.

One more number, because it is the one that gets missed. Keep the same 2,000 tonnes a month, and assume that because you lack verified installation data you have to declare a default value sitting 20 percent above the real figure of 1.8 tonnes of CO2 equivalent per tonne. Again, stated as an assumption. Declared emissions go to 2.16 tonnes per tonne, monthly embedded emissions to 4,320 tonnes, and at EUR 82.32 the monthly cost moves from about EUR 296,350 to about EUR 355,620. That is about EUR 59,270 a month and about EUR 711,000 a year. Set it against the EUR 25,350 monthly effect of the price rise that made the news. The data gap is more than twice the price move, and nobody puts the data gap in a headline.

Where does this conclusion flip? If allowance auction prices fall back, the certificate price follows them, and a programme that looked marginal at EUR 82.32 can look comfortable at a lower print; watch the auction results rather than the CBAM announcement, because the announcement is the lagged copy of the auction. If your supplier delivers verified installation data materially below the default value, your bill falls by more than any plausible price move, which is why the data request is a bigger lever than any price forecast. If you re-source inside the EU, CBAM no longer applies to the import, but the EU producer's price already carries its own allowance cost, so the saving is rarely the full certificate amount. And if your volumes are genuinely small, check with your national authority whether a de minimis threshold applies to you before you build an expensive compliance machine; thresholds and procedures are set nationally, so check there rather than assuming.

The premise underneath all of this is the rule Ingrid set out on what has to be true for an importer to fall inside the definitive regime at all and which transactions sit outside it. I am not restating it. What I want to leave you with is the document consequence: the regime converts an emissions figure into money, so that figure has to be sourced, versioned and defensible in exactly the way a customs value already is.

On alternatives, the honest ranking is not the one people expect. Switching to an EU source removes the CBAM obligation on the import, and the trap is assuming the price you are quoted is carbon-free; it is not, it embeds the supplier's own allowance cost, so compare landed cost with carbon in both columns. Switching to a supplier with better emissions data is often the cheapest move available, and the trap is accepting unverified data, because a spreadsheet from the mill is not verified installation data and will not survive a check. Holding certificates early is a legitimate hedge, and the trap is assuming you can hand back whatever you over-bought at the price you paid; the treatment of surplus certificates is set by your national authority and the terms are not a given, so check before you over-fund the account.

For the exporter outside the EU the same file runs in reverse, and the request arrives as a commercial one. Your EU customer will come back with something that reads like a customs questionnaire: which installation, which production route, which period, and is the figure verified. Suppliers who answer that quickly and cleanly will take volume from suppliers who do not, because the buyer's cash bill depends on your answer. Expect the request to land with a deadline and a fallback clause attached, and expect that a supplier who replies with a product brochure rather than a verified figure will be priced by the buyer as if it were the default value, since that is the only number the buyer can safely use.

One more timing question comes up in every conversation about the published numbers: which price applies to which goods. The certificate price is published for a period, and the obligation is calculated on the embedded emissions declared for what you imported. How your authority maps the two, and what happens at the boundary when publication moves from a quarterly to a weekly rhythm after 4 January 2027, is a question to put to that authority in writing rather than to guess at. This depends on the member state. I would rather you asked once and held a written answer than found out during a year-end reconciliation that your accrual used a different convention from the one the authority applies.

One operational habit changes the whole picture, and it is boring. Keep an emissions file per supplier per product, with the same discipline you already apply to a customs value: the source, the installation, the period, the verification status, the version, and the person who signed it off. When the authority asks why this figure and not another one, an email thread with a mill sales office is not an answer. When documents do not match, everything downstream becomes trouble, and here the mismatch is between your emissions file and your customs file, which is a gap nobody is watching today because the two have never had to agree before.

What to do now, who does it, and by when. Today, list every import line that is a CBAM good by CN code, and name the legal entity acting as declarant in each member state you import into; if nobody in the business can answer that within an hour, that is the finding and it is the one to fix before anything else. Before 4 January 2027, get verified installation-level emissions data into your supplier contracts, with a delivery date, the installation or route identified, and a stated consequence if the data does not arrive. Before the weekly regime starts, rewrite your price validity and pass-through clauses so the carbon line is either indexed to the certificate price or carried on a shorter validity, and set an internal rule for how much certificate cover you hold ahead of the surrender date. This is fixable, but requests for verified data have lead times measured in weeks at the mill, so the request has to go out this week.

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— By Derek Xu