CBAM certificates are specifically created for CBAM. They are separate from EU ETS allowances and are only available through the CBAM Registry from February 2027. The price link to the EU ETS is intentional: the goal is to ensure that imported goods face the same carbon cost as goods produced in the EU. Understanding the mechanics helps you plan cash flow and avoid both under-purchasing (which triggers penalties) and over-purchasing (where you lose unused certificates beyond the repurchase limit).
How CBAM certificate prices are set
CBAM certificate prices track the EU ETS auction price. The European Commission publishes one price per calendar quarter in 2026; from 2027 the price is published weekly. You cannot lock in a price in advance by buying certificates before you need them and holding them for months, because certificates have a shelf life within a calendar year only.
The EU ETS price in 2024-2026 has ranged between approximately EUR 50 and EUR 75 per tonne of CO2. This means your CBAM cost per tonne of imported goods depends on both the emissions intensity of the goods and the ETS price in the week you purchase the certificates.
Where you buy certificates
Certificates are purchased directly through the CBAM Registry, accessed via the EU Customs Single Window. You must be a registered authorised CBAM declarant to purchase. There is no secondary market for CBAM certificates. You cannot purchase them from another importer, from a financial intermediary, or from a carbon broker. Any offer to sell CBAM certificates outside the Registry is fraudulent.
When to purchase
There is no requirement to purchase certificates at the time of import. You can purchase at any point during the calendar year. However, the Regulation requires that at the end of each calendar quarter, your certificate holding covers at least 50% of the total embedded emissions you have imported since the start of that year. This is a rolling quarterly check to prevent importers from procrastinating entirely until the September deadline.
Article 22(2), Regulation (EU) 2023/956 (CBAM Regulation), as amended by Regulation (EU) 2025/2083: at the end of each calendar quarter, the authorised declarant must hold in the CBAM Registry an amount of CBAM certificates at least equal to 50% of the embedded emissions corresponding to all goods imported since the start of that calendar year. The competent authority may require additional certificates if it determines the holding is insufficient.
The surrender process at 30 September
After you file your annual CBAM declaration by 30 September, you surrender the number of certificates corresponding to the total embedded emissions declared. The surrender happens through the CBAM Registry: you confirm the quantity, and the Registry cancels those certificates from your account. The competent authority can verify that the quantity surrendered matches your declared emissions.
The matching must be exact. If you declared 1,200 tonnes of CO2 equivalent, you must surrender exactly 1,200 certificates. Surrendering fewer triggers the penalty provisions. Surrendering more is not possible, as the Registry does not accept surplus surrenders above the declared amount.
What happens to unused certificates
If you purchased more certificates than you needed, you can request repurchase by the competent authority for up to one third of the total you purchased in that year, at the original purchase price. The one-third cap is important: if you bought 1,500 certificates but only needed 900, the competent authority will repurchase up to 500 (one third of 1,500). The remaining 100 are cancelled without reimbursement.
This creates an incentive to estimate your emissions accurately before purchasing. Buying significantly more than you need is not a hedge against price increases; it is a partial cost write-off.
Practical cash flow planning
Build a monthly CBAM certificate budget based on your import plan. Estimate your embedded emissions per shipment, track cumulative purchases, and ensure each quarter-end holding meets the 50% minimum. Purchase certificates quarterly or as imports occur, rather than in a single year-end transaction, to spread the cash outflow and reduce your exposure to a single quarter's ETS price.
If you use EU default values, buy certificates based on the default emission figure. If you expect to receive verified actual data from your supplier before year-end, you can adjust your certificate holding downward when the data arrives and request repurchase of the excess, subject to the one-third limit.