CBAM Certificates: How to Buy, Hold the 50% Minimum, and Surrender in 2027

CBAM certificates go on sale February 1, 2027, and every authorized declarant importing goods from the six covered sectors must hold, manage, and surrender them against a verified embedded emissions total by September 30 of the same year. The certificate system is not a fee or a tariff: it is a quantity-based obligation set at the EU ETS carbon price, requiring importers to account for each tonne of CO₂e embedded in their goods. Understanding the three core actions (buying, holding the quarterly 50% minimum, and surrendering by the annual deadline) determines whether a business stays compliant or faces a €100 per tonne CO₂e penalty on top of a mandatory certificate purchase.

This article covers every stage of the CBAM certificate lifecycle: how the price is calculated from EU ETS auction data, how to project your obligation across four quarterly checkpoints, what the buyback right protects against, and when certificates from prior years get cancelled. The rules described here apply to the definitive phase under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.

What Are CBAM Certificates?

A CBAM certificate is an electronic instrument issued through the CBAM Registry that corresponds to one tonne of CO₂e of verified embedded emissions in goods imported under the six covered sectors: iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen. Certificates are defined in Article 3(10) of Regulation (EU) 2023/956. They are not tradeable on any exchange, not transferable between authorized declarants, and not usable for EU ETS compliance. Their only function is to be surrendered against a verified annual emissions total in the CBAM declaration filed each September 30.

The mechanism prevents carbon leakage by ensuring that imported goods carry the same carbon cost as goods produced inside the EU under the EU Emissions Trading System. The EU CBAM guide sets out this foundational linkage in full. Certificates are issued exclusively by national competent authorities (NCAs), held inside the CBAM Registry, and cancelled by the registry after surrender or on November 1 of the relevant cancellation year.

Four attributes define every CBAM certificate: the issuing NCA, the purchase date, the price paid (expressed as the applicable weekly average EU ETS auction closing price), and the vintage year. Vintage year matters because Article 24(1), as amended, cancels certificates from the year before the prior year on November 1 each year. Certificates purchased in 2027 that are not surrendered by September 30, 2027 are cancelled on November 1, 2027 if they predate the two-year window. Importers cannot accumulate a bank of certificates across more than two consecutive years.

Caption: The four-stage CBAM certificate lifecycle under Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.

How the CBAM Certificate Price Is Calculated

The CBAM certificate price equals the weekly average of EU ETS auction closing prices, published by the European Commission under Implementing Regulation (EU) 2025/2548. This pricing method applies from February 1, 2027 onward. For the calendar year 2026 (the first definitive-phase year, for which certificates are surrendered in September 2027), a different price formula applies: the quarterly average of EU ETS auction clearing prices under Article 22(1a), inserted by Regulation (EU) 2025/2083.

CBAM has no independent price. Certificate costs rise and fall in direct proportion to the EU ETS carbon price. As of late March 2026, the EU ETS price was approximately €70 per tonne CO₂ (range across Q1 2026: €66 to €90). Long-term analyst forecasts place the EU ETS price at €80 to €100 per tonne in 2027 and €100 to €150 per tonne by 2030. The CBAM price tracker publishes current and historical certificate prices updated each week from EU ETS auction data.

Caption: The CBAM certificate price equals the weekly average EU ETS auction closing price published each Monday by the European Commission under IR (EU) 2025/2548.

The table below shows the gross CBAM certificate cost at three reference price points across the six sectors:

These are gross figures. The net cost in 2026 is minimal because 97.5% of EU ETS free allocation for competing domestic producers remains. The CBAM factor in 2026 is 2.5%, meaning net certificate expenditure equals gross cost multiplied by 0.025. A BF-BOF steel importer paying €140 gross per tonne at €70/tCO₂ owes a net CBAM certificate cost of €3.50 per tonne in 2026. This figure grows steeply: the CBAM factor reaches 48.5% in 2030 and 100% in 2034 as free allocation is fully phased out.

How is the weekly average price published in practice? The Commission calculates and publishes a single certificate price each Monday, representing the average of all EU ETS auction clearing prices in the prior calendar week. Authorized declarants purchase certificates at this published price. The price does not vary intraweek once published.

How to Buy CBAM Certificates

Authorized declarants purchase CBAM certificates exclusively from their national competent authority through the CBAM Registry's certificate management module, which opens February 1, 2027. There is no secondary market, no certificate exchange, and no mechanism for one authorized declarant to sell certificates to another. All purchases flow through the NCA account in the registry.

The four steps for purchasing CBAM certificates are listed below.

1. Confirm authorization status. Only an authorized CBAM declarant can purchase certificates (Article 4, Regulation (EU) 2023/956). Authorization applications were due March 31, 2026. Importers without authorization cannot access the purchase module and face penalties of €300 to €500 per tonne CO₂e for unauthorized imports. The CBAM authorized declarant requirements are covered separately in the compliance section of this site.
2. Access the CBAM Registry. Log in through the EU Customs Trader Portal using UUM&DS authentication (the same system used for EU ETS registry access). Your CBAM account shows your current certificate holdings, import transaction history fed in by customs authorities, and the current published certificate price.
3. Calculate the quantity needed. Determine how many certificates to purchase based on your cumulative embedded emissions to date and the quarterly holding requirement (see the next section). Certificates are denominated in whole tonnes of CO₂e.
4. Submit the purchase order. Place the purchase order through the Common Central Platform operated by DG TAXUD. Payment is at the current weekly average EU ETS auction closing price. Certificates appear in your registry account immediately upon purchase confirmation.

How many certificates should you purchase at once? Buying in quarterly tranches aligned with the holding requirement check dates (March 31, June 30, September 30, December 31) is the most operationally efficient approach. Authorized declarants with large and predictable import volumes typically purchase incrementally as volumes accumulate across the year rather than attempting a single annual purchase before the surrender deadline.

The 50% Quarterly Holding Requirement

The quarterly holding requirement obliges every authorized declarant to hold, at the end of each calendar quarter, CBAM certificates equal to at least 50% of the cumulative embedded emissions of all CBAM goods imported since January 1 of that calendar year. This rule comes from Article 22(2) as amended by Regulation (EU) 2025/2083. The threshold was reduced from 80% by the Omnibus simplification to give importers more financial flexibility within each quarter.

The four quarterly check points and their calculation basis are shown below:

Notice that the base is cumulative from January 1, not just within the quarter. This means each successive quarter check is calculated against a growing total. An importer who imported 1,000 tonnes CO₂e in Q1 and another 1,000 tonnes CO₂e in Q2 must hold certificates covering at least 1,000 tonnes (50% of the 2,000-tonne cumulative H1 total) at June 30, not just 500 tonnes.

A worked example using BF-BOF steel at a €70/tCO₂ certificate price illustrates the quarterly calculation:

• Q1 imports: 500 tonnes of BF-BOF steel × 2.0 tCO₂/t = 1,000 tCO₂e
• Required holdings at March 31: 1,000 × 50% = 500 certificates (cost: 500 × €70 = €35,000)
• Q2 imports: 500 tonnes of BF-BOF steel × 2.0 tCO₂/t = additional 1,000 tCO₂e
• Cumulative H1 total: 2,000 tCO₂e
• Required holdings at June 30: 2,000 × 50% = 1,000 certificates (already hold 500; need to buy 500 more; cost: 500 × €70 = €35,000)

The registry records your holdings in real time. NCAs can check compliance with the quarterly minimum at the close of each quarter. Failure to maintain the 50% minimum at any quarter end triggers the standard penalty of €100 per tonne CO₂e for the shortfall, even if the importer plans to reach full compliance before the September 30 annual surrender.

What emissions data feeds the quarterly calculation? The embedded emissions used for quarterly holding checks come from the importer's own records of imported goods crossed against verified or estimated specific embedded emissions. Where verified data is not yet available (verifiers cannot register until September 1, 2026), importers use default values published in Implementing Regulation (EU) 2025/2621. Default values carry mark-ups of 10% in 2027, making them more expensive than verified actual emissions in most cases. Specific embedded emissions calculation methods for each sector are covered in the CBAM embedded emissions article in the compliance section.

Caption: The 50% quarterly holding requirement accumulates against total embedded emissions from January 1, not just within each individual quarter.

How to Surrender CBAM Certificates

Certificate surrender is the act of transferring the required number of CBAM certificates from your registry account to the competent authority in settlement of your annual CBAM declaration. Surrender is executed through the CBAM Registry at the point of filing the annual declaration. The deadline for surrender is September 30 each year, covering the full prior calendar year. The first surrender deadline is September 30, 2027, covering calendar year 2026 imports.

The surrender process follows these five steps:

1. Obtain verified embedded emissions totals. The total quantity surrendered must equal the verified embedded emissions declared in the annual CBAM declaration. All embedded emissions data submitted in the declaration must be verified by an accredited verifier under Delegated Regulation (EU) 2025/2551. Verifiers can register in the CBAM Registry from September 1, 2026.
2. Calculate the net surrender obligation. Subtract any Article 9 deductions for carbon prices effectively paid in the country of origin. Subtract the SEFA adjustment (the reduction attributable to EU ETS free allocation still received by competing domestic producers, calculated under Implementing Regulation (EU) 2025/2620). The result is the net number of certificates to surrender.
3. Confirm certificate holdings are sufficient. Your CBAM Registry account must hold certificates equal to or greater than the net surrender obligation at the time of filing. If a shortfall exists, purchase additional certificates before submitting the declaration.
4. File the CBAM declaration. Submit the annual declaration through the CBAM Registry to your NCA. The declaration must include: total quantity of CBAM goods by type and country of origin, total verified embedded emissions, certificates surrendered, and documentation of any Article 9 deductions claimed. Full declaration content requirements are defined in Article 6 of Regulation (EU) 2023/956.
5. Confirm surrender and retain records. The registry cancels surrendered certificates and issues a confirmation. Retain all supporting documentation, including customs declarations, verification reports, certificate purchase records, and Article 9 deduction evidence, until the end of the 4th year following the declaration year.

What documentation is filed alongside surrender? The CBAM declaration requires verification report references, embedded emissions breakdowns by production installation, and evidence of Article 9 deductions. The CBAM declaration article details every required document field.

The Buyback Right: Protecting Against Over-Purchase

Authorized declarants can sell back up to 50% of the CBAM certificates purchased in a given calendar year, at the price they originally paid, to their national competent authority. The buyback right is established in Article 23 as amended by Regulation (EU) 2025/2083, and the deadline for exercising it is October 31 of the surrender year. This means the buyback window for 2027 purchases closes October 31, 2027, one month after the September 30 surrender deadline.

The buyback protects against a specific operational risk: an importer buys certificates in advance based on a projected import volume, but actual imports fall short of the projection due to demand changes, supply chain disruptions, or commodity price shifts. Without buyback, the importer would hold excess certificates that expire worthless on November 1. With buyback, the importer recovers the purchase cost for up to half the certificates they bought in that year.

Three practical points about buyback management are worth noting. First, the 50% buyback limit is calculated on total purchases for the year, not on individual transactions. An importer who purchased 1,000 certificates in 2027 can sell back up to 500 of them. Second, the buyback price is fixed at the price paid on purchase, not the price on the buyback date. An importer who purchased at €70/tCO₂ and buys back at a date when the market price is €85/tCO₂ recovers only €70/tCO₂. Third, the buyback does not require justification or approval beyond the administrative request. It is an unconditional right exercisable within the October 31 deadline.

Certificate Cancellation: The November 1 Rule

Every November 1, the CBAM Registry cancels all certificates from the year before the prior year. In practical terms, certificates with a vintage of two years ago are cancelled on November 1 of the current year. For example, on November 1, 2029, all 2027-vintage certificates still in any authorized declarant's account are permanently cancelled with no compensation. This rule comes from Article 24(1) as amended.

The cancellation cycle creates a strict two-year holding window. Authorized declarants cannot carry forward certificates indefinitely as a hedge against future price increases. The maximum useful life of any certificate purchased is approximately 22 months, from the earliest purchase date (February 1, 2027) to the latest possible cancellation date (October 31, 2028 for the buyback window, or November 1, 2028 for cancellation). Any certificate from 2027 not sold back by October 31, 2028 and not surrendered in the September 30, 2028 declaration is cancelled November 1, 2028.

Caption: CBAM certificates from any given year are permanently cancelled on November 1 two years later if not surrendered or bought back.

The cancellation timeline across the first three active years is shown below:

This table assumes certificates are purchased for the same year's obligation. Certificates purchased in 2027 intended for use in the 2027 declaration (covering 2027 imports) have their buyback deadline on October 31, 2027, and are cancelled November 1, 2028 if any remain. The system intentionally prevents stockpiling.

What Happens If You Do Not Surrender Enough Certificates?

Failure to surrender sufficient CBAM certificates by September 30 triggers a penalty of €100 per tonne CO₂e of the shortfall under Article 26(1) as amended by Regulation (EU) 2025/2083. The €100 rate is fixed, inflation-adjusted, and identical to the EU ETS excess emissions penalty. This equivalence is a deliberate design choice to maintain consistency between the internal carbon market and the border adjustment.

The penalty does not replace the obligation. An importer who fails to surrender certificates covering 500 tCO₂e must pay the €100 penalty (€50,000) AND still procure and surrender the missing 500 certificates at the prevailing market price. At €70/tCO₂, the total cost of non-compliance on that shortfall is €50,000 (penalty) plus €35,000 (certificate purchase) equals €85,000, or €170 per tonne CO₂e. At €100/tCO₂, the combined cost reaches €200 per tonne CO₂e.

Unauthorized importers face a steeper sanction. Importing CBAM goods without authorization triggers penalties of €300 to €500 per tonne CO₂e, representing three to five times the standard authorized-declarant rate. The penalty range reflects the severity of bypassing the authorization system entirely.

How CBAM Certificates Connect to the Free Allocation Phase-Out

The net cost of CBAM certificate surrender grows every year as EU ETS free allocation for CBAM sectors is phased out between 2026 and 2034 under Article 10a(1a) of ETS Directive 2003/87/EC. The CBAM factor, which determines the fraction of the gross certificate obligation that applies as a net cost, follows the schedule below:

The steepest acceleration falls between 2029 and 2030, when the CBAM factor more than doubles from 22.5% to 48.5%. An importer of BF-BOF steel paying a net €31.50 per tonne in 2029 will pay €67.90 per tonne in 2030 at the same ETS price. The purchasing strategy for 2026 and 2027, when certificate costs are still modest, does not represent the financial exposure that will arrive after 2028.

The SEFA methodology (Specific Embedded Free Allocation, under Implementing Regulation (EU) 2025/2620) calculates the precise reduction in each importer's surrender obligation arising from free allocation still flowing to competing EU domestic producers. The SEFA ensures that the certificate obligation corresponds only to the net competitive disadvantage, not to any carbon costs that EU producers also absorb for free.

When to Purchase Certificates: Timing and Price Risk

All authorized declarants face the same pricing structure: certificates are purchased at the weekly average EU ETS auction closing price published each Monday. No forward-locking mechanism exists under the regulation. Importers who want price certainty must use their own financial instruments (such as ETS allowance forwards, which are traded on financial markets) independently of the certificate purchase process.

Three timing approaches are common among large importers, each with different cost and risk profiles:

• Rolling quarterly purchase: Buy certificates at each quarter-end check to satisfy exactly the 50% minimum. This approach defers cash outlay but exposes the importer to price movements across the year. If the EU ETS price rises between Q1 and Q4, certificates purchased in Q4 cost more than those purchased in Q1.
• Front-loaded annual purchase: Buy the full projected annual obligation in February or March at the start of the certificate sales window. This avoids price risk from rising markets but creates excess certificate risk if actual imports are lower than projected. The buyback right (capped at 50%) partially mitigates this exposure.
• Proportional monthly purchase: Buy each month in proportion to that month's import volume and embedded emissions. This approach averages the purchase price across 12 months (a cost-averaging strategy) and keeps quarterly holdings above the 50% threshold without concentrating financial exposure in any single quarter.

What if the EU ETS price falls significantly? Importers who purchased certificates at a high price and wish to reduce holdings can use the buyback right for up to 50% of that year's purchases. For the other 50%, they must hold and surrender or allow cancellation. The regulation provides no mechanism for a declarant to profit from price differences between purchase and surrender periods.

Key Deadlines Summary

The annual certificate compliance cycle, from the opening of sales to cancellation, spans 21 months for any given year's obligation. The complete timeline for the 2027 compliance year is listed below:

• February 1, 2027: Certificate sales open. Authorized declarants can begin purchasing for calendar year 2027 imports.
• March 31, 2027: First quarterly holding check. Holdings must cover at least 50% of Q1 2027 embedded emissions.
• June 30, 2027: Second quarterly holding check. Holdings must cover at least 50% of cumulative H1 2027 embedded emissions.
• September 1, 2026 (preceding year): Verifiers may register in CBAM Registry. Importers should contract verifiers now for 2026-year verification.
• September 30, 2027: Annual surrender deadline. CBAM declaration for calendar year 2026 imports (the first declaration) must be filed, and certificates surrendered. The first surrender covers 2026 embedded emissions, priced at the quarterly average EU ETS price for each quarter in 2026 (not the 2027 weekly average).
• September 30, 2027 (continuing): Also the quarterly check date for Q3 2027 holdings.
• October 31, 2027: Buyback deadline for 2027 purchases. Sell back up to 50% of 2027 certificates to the NCA at the purchase price.
• November 1, 2027: Any 2025-vintage certificates (not yet applicable, since sales began February 2027) would be cancelled. For practical purposes in the first year, no pre-2027 certificates exist.
• December 31, 2027: Fourth quarterly holding check. Holdings must cover at least 50% of full-year 2027 cumulative embedded emissions.
• November 1, 2028: All 2027-vintage certificates remaining in any account are permanently cancelled.

CBAM Certificate Compliance: Common Questions

Can You Sell CBAM Certificates to Other Authorized Declarants?

No. CBAM certificates are not transferable between authorized declarants. The only mechanism to return certificates is the buyback right under Article 23, which applies exclusively to sales back to the national competent authority at the original purchase price. Trading CBAM certificates between companies is prohibited under the regulation. This distinguishes CBAM certificates from EU ETS allowances, which can be traded on the ETS market between installations and third-party traders.

Is There a Minimum Number of Certificates to Hold Each Quarter?

Yes. The minimum at any quarter end is 50% of cumulative embedded emissions since January 1 of that year. The obligation applies independently at each of the four quarter-end dates: March 31, June 30, September 30, and December 31. Failing to meet the minimum at any single quarter-end checkpoint triggers the €100 per tonne CO₂e penalty on the shortfall, even if the importer plans to be fully compliant before the September 30 annual deadline.

Does the CBAM Certificate Price Change After Purchase?

No. Once purchased, the certificate's recorded price is fixed at the weekly average EU ETS auction closing price that was in effect on the purchase date. Subsequent changes to the EU ETS price do not retroactively alter the cost of certificates already held. Price risk runs only in the forward direction: certificates not yet purchased are subject to future EU ETS price movements.

What Is the Penalty for Submitting the Wrong Embedded Emissions Total?

Submitting a fraudulent or materially incorrect embedded emissions declaration carries consequences beyond the standard €100 per tonne shortfall penalty. Article 26 and Recital 26 of Regulation (EU) 2023/956 align the response to fraudulent declarations with EU ETS excess emissions penalty structures, which can include authorization revocation, customs sanctions, and potential criminal referral under member state law. Verification by an accredited verifier under Delegated Regulation (EU) 2025/2551 is the primary mechanism for ensuring embedded emissions accuracy.

Can an Importer Use Default Values for the Certificate Obligation?

Yes. Importers who cannot obtain specific verified embedded emissions data from their suppliers may use default values published in Implementing Regulation (EU) 2025/2621. Default values are set at country-specific average emission intensities for each sector and product type, with punitive mark-ups of 10% above the calculated default in 2027, 20% in 2028, and 30% from 2028 onward (fertilizers receive a 1% mark-up across all years). Using defaults inflates the certificate obligation compared to what verified actual emissions would require. Importers with actual emissions below the default have a growing financial incentive to obtain and verify specific data from 2027 onward.

Does the Quarterly Holding Requirement Apply in 2026?

No. The quarterly holding requirement applies only from February 1, 2027, when certificate sales open. Calendar year 2026 is the first definitive-phase year, but no certificates exist until February 2027. The embedded emissions accumulated during 2026 become the first surrender obligation filed September 30, 2027. Until the certificate market opens, there is no holding requirement to enforce.

Related Compliance Topics

How Embedded Emissions Determine the Certificate Obligation Size

The number of certificates an importer must surrender equals the total verified embedded emissions of all CBAM goods imported in a calendar year, measured in tonnes of CO₂e, after applying SEFA adjustments and any Article 9 deductions. The embedded emissions figure is not based on import value or weight alone. It is a function of the specific embedded emissions per tonne of goods from each production installation, multiplied by the import tonnage. Sectors such as cement and fertilizers include both direct and indirect (electricity-related) emissions; sectors such as iron and steel cover direct emissions only. The full calculation framework for each sector is explained in the CBAM embedded emissions article.

Are Embedded Emissions from Different Countries Treated the Same?

Embedded emissions from different countries of origin are calculated using the same methodology but produce different results because specific embedded emissions vary by production technology and fuel mix. A tonne of BF-BOF steel from a coal-intensive Turkish mill carries approximately 2.0 tCO₂/t embedded emissions; a tonne of EAF scrap-based steel from a European-equivalent facility in South Korea may carry approximately 0.5 tCO₂/t. Countries with no equivalent carbon pricing scheme (such as Turkey, India, and Russia) allow no Article 9 deduction, meaning the full CBAM certificate obligation applies. South Korea's K-ETS price is pending Commission assessment for potential partial deduction status as of April 2026.

How Authorization Determines Who Can Purchase

Only an authorized CBAM declarant can access the certificate purchase module in the CBAM Registry. Authorization requires a clean 5-year customs and tax compliance history, an active EORI number, and a valid application submitted to the competent authority of the member state of establishment. The authorization application deadline was March 31, 2026. Importers who missed this deadline and are importing CBAM goods without authorization face the three-to-five-times penalty rate (€300 to €500 per tonne CO₂e) rather than the standard €100 rate. The authorization process, required documents, and NCA contacts are detailed in the CBAM authorized declarant article.

Is Authorization Revocable After It Is Granted?

Yes. The NCA can revoke authorization under grounds specified in Implementing Regulation (EU) 2025/486 and its amendment IR 2025/2549. Grounds include: subsequent customs violations, tax fraud conviction, insolvency proceedings, material misrepresentation in the application, and ongoing failure to comply with CBAM obligations. Revocation is treated seriously because a revoked authorized declarant loses the ability to import CBAM goods legally and may face penalties for any imports made after revocation.

How CBAM Reporting Supports the Surrender Process

The annual CBAM declaration filed at surrender is not a standalone document. It integrates data collected continuously throughout the year: import records, verified embedded emissions reports, Article 9 carbon price evidence, and SEFA adjustment calculations. All of this documentation must be retained until the end of the 4th year following the declaration year. The CBAM reporting article sets out the full record-keeping framework and explains which documents the national competent authority may request during a risk-based inspection under Article 15.

Verifiers play a central role in the reporting chain. Every production installation supplying CBAM goods to an EU importer requires an accredited verifier to confirm its specific embedded emissions. Verifiers must register in the CBAM Registry from September 1, 2026, and must conduct a mandatory physical site visit for every first-period verification. The verification report is the primary evidence document in the annual CBAM declaration.