From February 2027 onwards, EU companies have to purchase CBAM certificates for the embedded emissions in imported CBAM goods. The rules for the purchase and resale of the CBAM certificates have now been detailed in a delegated act (draft). A CBAM certificate strategy will become a key pillar to manage financial CBAM obligations.
(Last update on 15/07/2026)
Why CBAM certificates matter
Carbon pricing in the EU Carbon Border Adjustment Mechanism (CBAM) will be instrumented through CBAM certificates. Each tonne of embedded emissions in imported CBAM goods needs to be covered by one CBAM certificate. The carbon prices for these certificates determine the CBAM costs for importers.
These costs are already material for all CBAM imports since January 1, 2026. From February 2027, authorised CBAM declarants will be able to purchase the required certificates and surrender them against declared emissions – retroactively for imports in 2026 and on a continuing base for all further imports.
The CBAM Regulation (EU) 2023/956 establishes the core for the sale, pricing, surrender, repurchase and cancellation of CBAM certificates in Articles 20 to 24. The operational requirements are further detailed by implementing and delegated act to set the CBAM rulebook.
Implementing regulation (IR) 2025/2548 establishes how the price to be paid for CBAM certificates is calculated and published:
- on a quarterly base for 2026 imports;
- weekly for imports from 2027 onwards.
Now, the European Commission (EC) has published the draft delegated act for the management of CBAM certificates. It specifies how purchases and resales work. The draft is open for consultation until August 6. It applies from February 1, 2027.
How CBAM certificates are purchased and managed
From an importer perspective, CBAM certificate management has four steps: purchase, surrender, possible repurchase and cancellation. These steps form the CBAM certificate lifecycle. A smart procurement strategy allows for the hedging of price fluctuations.
Purchasing CBAM certificates
CBAM certificates cannot be bought via a market. From 1 February 2027, users as authorized CBAM declarants can enter a purchase request into the CBAM Registry by determining the number of CBAM certificates to buy.
The request is then transferred to the Common Central Platform through which EU Member States sell the required CBAM certificates to CBAM declarants as per Article 20 of the CBAM regulation 2023/956. There is no cap on the number of certificates available and Member States cannot delay or restrict sales.
After payment is confirmed, the certificates are created in the declarant account with the following information:
- the unique identification number of the CBAM certificate;
- the unique CBAM account number of the user;
- the Member State where the user is established;
- the price of the CBAM certificate;
- the date of credit;
- the status of the CBAM certificate.
According to Article 21, the price of CBAM certificates follows the EU Emissions Trading System (ETS). For 2026, prices are set quarterly. From 2027 onwards, the EC calculates a weekly certificate price based on the average prices of EU ETS allowances auctioned during the relevant week.
In addition, a fixed fee of EUR 0.05 per certificate applies to finance the Common Central Platform.
Surrendering CBAM certificates
The purpose of purchasing certificates is to surrender them against annual CBAM obligations as per Article 22 of the CBAM regulation 2023/956. By 30 September each year, authorized CBAM declarants must submit a CBAM declaration for the previous calendar year.
An equivalent number of CBAM certificates will be surrendered upon submission of the declaration. The number of certificates to be surrendered takes into account the adjustment for free allocations and carbon price deductions. The certificates surrendered will be removed from the declarant’s account.
In addition to the annual surrender obligation, importers must maintain a minimum quarterly certificate holding. From 2027, the number of certificates held at the end of each quarter must correspond to at least 50 percent of estimated quarterly needs. This minimum holding requirement is calculated based on:
- Default values (without mark-ups) for embedded emissions; or
- Number of CBAM certificates surrendered in the previous calendar year –provided that the imports stay the same.
Repurchase of CBAM certificates
CBAM recognizes that companies may purchase too many certificates. For this reason, Article 23 of the CBAM Regulation 2023/956 establishes a repurchase mechanism. A CBAM declarant may request the repurchase of excess certificates. Requests must be submitted by 31 October.
The EC will repurchase the requested CBAM certificates on behalf of the Member State where the Declarant is authorized. The repurchase price is the same price paid when the certificate was purchased.
The mechanism is subject to limits. In general, only certificates linked to the quarterly holding obligation may be repurchased. The delegated act also limits users to one repurchase request per year and requires that annual surrender obligations have been fulfilled before repurchase takes place.
Cancellation of CBAM certificates
Repurchase does not remove all risks associated with over-purchasing. According to Article 24 of the CBAM Regulation 2023/956, on 1 November each year, the EC will cancel certificates purchased during the year before the previous calendar year that still remain on the account.
No compensation is paid for cancelled certificates. This makes forecasting and certificate management important. Companies that systematically buy too many certificates may ultimately lose their value through cancellation.
How companies can prepare for CBAM certificates
CBAM certificates are the means through which CBAM becomes a financial obligation. They connect imports and their embedded emissions with carbon prices.
Importing companies can prepare the CBAM certificate procurement starting 2027:
- Forecast CBAM certificate demand based on reliable data for import volumes and emission values;
- Procure CBAM certificate based on clear rules for purchasing volumes and timing – interacting with hedging and risk management strategies;
- Track CBAM certificate purchases against forecasted demand and balances from earlier periods to optimize cash flow and compliance requirements.
For importing companies, the key question is no longer only how emissions are reported. It is also how certificate demand is forecasted and managed.
Although some regulatory details still need to be clarified (e.g. which certificates are to be surrendered), importing companies need operational rules and responsibilities for the purchase of CBAM certificates.
A procurement strategy will become a key pillar to manage financial CBAM obligations and hedge carbon price risks.
Sources and further information:
- EU: Regulation Establishing CBAM (2023/956)
- EC: Sale and Repurchase of CBAM Certificates (draft)
Photo by Wolfgang Weiser on Unsplash
