CBAM in 2027: Buying Certificates and the First Declaration

In 2026 the EU Carbon Border Adjustment Mechanism became a financial obligation, but no importer has paid anything yet. That changes in 2027. Two things happen in the same year: importers buy and surrender certificates for what they imported in 2026, and everything imported in 2027 is priced on stricter terms. This guide covers both, for exporters anywhere outside the EU.

The 2027 timeline

1. 1

   January 2027: a new import year begins

   Goods imported from 1 January 2027 carry the 2027 terms: a 20% mark-up on default values and a 95% CBAM factor for the free-allocation deduction.

2. 2

   February 2027: certificate sales open

   Authorised CBAM declarants can buy certificates on the central platform. From 2027 the price is published weekly.

3. 3

   Every quarter: hold enough certificates

   At the end of each quarter a declarant must hold certificates covering at least 50% of the embedded emissions of its imports so far that year, down from 80% before the 2025 simplification.

4. 4

   30 September 2027: first declaration and surrender

   Each declarant files its annual CBAM declaration for 2026 imports and surrenders the certificates, using verified actual data where its suppliers provided it and default values everywhere else.

What a 2027 import costs on default values

Two numbers move against the importer each year. The mark-up on default values rises from 10% to 20%, and the CBAM factor, the share of the EU benchmark deducted because EU producers still get free allowances, falls from 97.5% to 95%. Both raise the number of certificates per tonne even if nothing about the steel changes.

At the Q3 2026 price of €82.32, 1,000 tonnes imported in 2027 would need about 3,835 certificates, roughly €315,700, against €277,600 for the same tonnes in 2026. The real 2027 price will be set by the weekly auction average, and the Commission is updating the benchmarks for 2027 imports, so treat the 2027 figure as today's best estimate. The calculator below lets you enter your own price.

What exporters need to have ready

The 30 September 2027 declaration covers goods imported in calendar year 2026. If your EU customer is to declare your actual emissions instead of defaults, the following has to be in their hands before they file:

• Verified 2026 emissions for each installation, from a verifier accredited under the CBAM rules. The reporting period is the calendar year.
• Specific embedded emissions per good, per CN code, including the precursors you consumed. How to calculate them walks through one mill.
• The communication to your importer: the emissions report summary for declarants and, where needed, a confidential addendum for that declarant.
• Evidence of any carbon price paid in your own country, if a deduction will be claimed. The implementing rules for that deduction were still in draft in 2026.

Verifier capacity is the bottleneck in the first year, so the safest plan is to close the 2026 monitoring data in January and book the verification for the first quarter of 2027.

Also starting in 2027: the UK CBAM

The United Kingdom's own carbon border adjustment starts on 1 January 2027, for importers of £50,000 or more of covered goods a year. HMRC published illustrative rates in October 2026; registration opens on 1 January 2028 and the first return and payment, for 2027, is due on 31 May 2028. Exporters selling steel or aluminium into both the EU and the UK will report to two different schemes from the same plant data. See UK CBAM 2027: first rates.

A checklist for the next twelve months

• List every EU customer, the CN codes you ship them and whether each exceeds the 50-tonne annual threshold.
• Close 2026 installation data (fuel, electricity, process inputs, production) by January 2027.
• Collect verified precursor figures from your own suppliers.
• Book an accredited verifier for Q1 2027.
• Send each importer its communication by mid-2027, well before 30 September.
• Run your 2027 and 2028 shipments through the default-value calculation, so price talks start from the real gap.

ZeroCarbon calculates embedded emissions per good from your bills and production records, compares them with the default your buyer would otherwise use, and prepares the verifier pack and importer communication. Check your goods in the free CBAM cost calculator, or request a workspace to prepare your 2026 figures.