CBAM certificate cost in 2027: what changes on 1 January and what changes on 1 February

The CBAM definitive period began on 1 January 2026, but nobody has yet bought a certificate. Regulation (EU) 2025/2083, in force since 20 October 2025, moved the whole payment cycle for 2026 imports into 2027 and set two different dates for two different things. One changes how much of each tonne is chargeable and how the price is set. The other opens the shop. This page separates them. It is Bindler's reading; the regulation controls.

1 January 2027: the chargeable share doubles and the price rule changes

Two things happen on the first day of 2027, and both come from texts other than the October 2025 amendment.

The CBAM factor rises from 2.5 percent to 5 percent. Free allocation under the EU ETS for CBAM sectors is phased out on a schedule written into Directive (EU) 2023/959, Article 10a(1a): 97.5 percent free in 2026, 95 percent in 2027, 90 percent in 2028, then 77.5, 51.5, 39, 26.5, 14 and zero in 2034. The CBAM factor is the mirror image, so the share of embedded emissions on which certificates are owed goes from 2.5 percent for goods imported in 2026 to 5 percent for goods imported in 2027. Same tonnes, same emissions, twice the certificates. The certificate price moves to a weekly average. Article 21 of Regulation (EU) 2023/956 as amended prices certificates on the average closing price of EU ETS allowances on the auction platform for each calendar week. That weekly rule is the general one and it applies to embedded emissions declared for 2027 onwards. For 2026 it is displaced by a special rule, below.

Together these mean that the first January of the definitive period with a real cost signal is 2027, not 2026. An importer whose 2026 basket is priced on a quarterly average at a 2.5 percent factor will see the 2027 basket priced on weekly averages at 5 percent.

1 February 2027: certificates go on sale

Under Article 20(1) as amended by Regulation (EU) 2025/2083, from 1 February 2027 each Member State sells CBAM certificates to the authorised declarants established in it, on a common central platform that the Commission establishes and manages after a joint procurement with the Member States (Article 20(2)). The seller is the Member State, the shop is the Commission's. Until that day no certificate exists to buy. The information on sales and repurchases moves from the platform to the CBAM registry at the end of each working day (Article 20(3) as amended).

The price of the certificates that cover 2026 imports is not the weekly figure. Under the new Article 21(1a), the Commission calculates the price for embedded emissions declared in respect of 2026 as the quarterly average of the closing prices of EU ETS allowances on the auction platform for the quarter in which the goods were imported. Goods imported in March 2026 are priced on the first-quarter 2026 average; goods imported in November 2026 on the fourth-quarter average. The buying happens in 2027, the price is fixed by 2026. That is a known quantity by the time the platform opens, which is the point of the derogation.

What the 2027 calendar looks like for a 2026 importer

The obligations that fall due in 2027, in order, all from Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083:

• 1 February 2027: certificate sales open on the central platform.
• 30 September 2027: the first annual CBAM declaration, covering 2026, is submitted through the CBAM registry (Article 6(1)), and on the same day the matching certificates are surrendered (Article 22(1)). The old deadline of 31 May is gone.
• 31 October 2027: last day to ask the Commission to repurchase excess certificates for the year (Article 23). Certificates bought in 2027 for 2026 emissions can only be repurchased in 2027 (Article 23(2a)).
• 1 November each year: the Commission cancels, without compensation, any certificates bought during the year before the previous calendar year that are still on the account (Article 24(1)). For the 2027 purchases that first bites on 1 November 2029.

A declarant that fails to surrender enough certificates by 30 September pays the penalty in Article 26(1) as amended: the ETS excess emissions penalty of Directive 2003/87/EC, EUR 100 for each tonne of embedded emissions not covered, indexed as that penalty is, with the competent authority able to reduce it for minor or unintentional errors. Paying it does not cancel the duty to surrender the missing certificates. An importer that passes the 50-tonne threshold without authorisation faces three to five times that amount per tonne (Article 26(2) as amended).

The quarter-end holding rule

From 2027 an authorised declarant must, at the end of each quarter, hold certificates covering at least 50 percent of the embedded emissions in the goods it has imported since the start of the year (Article 22(2) as amended, down from 80 percent). The repurchase limit is tied to the same figure: the Commission buys back no more than the number of certificates the declarant was obliged to buy under Article 22(2) during the year of purchase (Article 23(2)). A declarant that bought certificates expecting to exceed the 50-tonne mass threshold and then did not has all of them repurchased on request.

Who this applies to

The threshold is the single mass-based one: 50 tonnes net, cumulative over the calendar year, across iron and steel, aluminium, fertilisers and cement together (Article 2a and Annex, as amended). Electricity and hydrogen sit outside it. Under 50 tonnes there is no declaration, no certificate and no 2027 bill. Over it, the importer needs authorised CBAM declarant status, and the 2026 quantities have to be on record now because the September 2027 declaration covers all of them.

Running your own number

The free CBAM cost estimator prices one import line for any year from 2026 to 2034 with the factor schedule above, so the 2026 to 2027 jump can be seen on your own tonnage and a price of your choosing. The EU CBAM Cost Calculator 2026 to 2034 ($29, /cbam-calculator/) carries the same schedule on a Factors sheet with its source, prices a whole basket, and runs a nine-year projection with a price sensitivity grid, so the quarter-end holding and the September surrender can be budgeted rather than guessed. The definitive period timeline lists every date to 2034, and the cost guide explains the arithmetic behind the estimator.

Sources

• Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism, OJ 17 October 2025: Articles 6(1), 20, 21(1a), 22(1) and (2), 23, 24(1), 26 and the Annex (50 tonnes): eur-lex.europa.eu/eli/reg/2025/2083/oj (CELEX 32025R2083). EUR-Lex served an empty page to our reader on 28 September 2026, so the article readings above were cross-checked against Mayer Brown, EU Adopts CBAM Simplification Regulation: 10 Key Amendments (October 2025), mayerbrown.com, and Regulatory Compliance EU, CBAM certificates: sale and repurchase (15 July 2026), regulatory-compliance.eu.
• Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism: eur-lex.europa.eu/eli/reg/2023/956/oj.
• Directive (EU) 2023/959, Article 10a(1a) of Directive 2003/87/EC as amended, the free allocation phase-out: eur-lex.europa.eu/eli/dir/2023/959/oj.
• European Commission, CBAM certificate price page: taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en.

Last checked against the sources on 28 September 2026.