CBAM certificates become available for purchase on February 1, 2027, when national competent authorities (NCAs) open the Common Central Platform for authorized declarants. Every authorized declarant importing CBAM-covered goods into the EU must understand the purchase process, the pricing mechanism, and the quarterly holding requirement before that date arrives.
This guide covers the complete certificate purchase process under Regulation (EU) 2023/956 as amended by the Omnibus Regulation (EU) 2025/2083: where to buy, how the price is set, how much to hold, and how the buyback provision reduces financial risk.
Caption: CBAM certificates are purchased exclusively through national competent authorities via the EU CBAM Registry, not through any secondary market or exchange.
What Are CBAM Certificates and Why Authorized Declarants Must Hold Them
CBAM certificates are EU regulatory instruments, each representing one tonne of CO₂ equivalent, that an authorized declarant must purchase and surrender to cover the embedded emissions of CBAM goods imported into the EU. They are not tradeable securities. They cannot be bought on an exchange, transferred between companies, or sourced from a broker. Every certificate flows through the national competent authority of the member state where the authorized declarant is established.
The obligation to hold and surrender CBAM certificates applies to every authorized declarant importing iron and steel, cement, aluminium, fertilizers, electricity, or hydrogen that exceeds the 50-tonne annual de minimis threshold. Electricity and hydrogen have no de minimis exemption — all volumes require certificate coverage regardless of quantity.
The EU carbon border adjustment mechanism links the certificate price directly to the EU ETS carbon price, which stood at approximately €70 per tonne CO₂ in late March 2026. This connection means certificate costs rise and fall with EU ETS auction outcomes, creating a continuous budgeting variable for importers.
How CBAM Certificate Prices Are Set: 2026 vs 2027 Onward
The pricing method for CBAM certificates differs between the first compliance year and all subsequent years. The table below sets out both methods under Article 22 of Regulation (EU) 2023/956, as amended by the Omnibus.
| Period | Price Basis | Regulation Article | Practical Implication |
|---|---|---|---|
| 2026 imports | Quarterly average of EU ETS auction clearing prices | Article 22(1a), inserted by 2025/2083 | Price is known in arrears per quarter; importers can calculate 2026 liability once all 4 quarterly averages are published |
| 2027+ imports | Weekly average of EU ETS auction closing prices | Article 22(1) | Price updates weekly; importers buying throughout the year face a fluctuating purchase price |
| Buyback price | Original purchase price | Article 23, as amended | No gain or loss on returned certificates |
For 2026 imports, the quarterly averaging method works in the authorized declarant's favor: by the time certificates go on sale on February 1, 2027, all four 2026 quarterly averages are already known. This means the total certificate cost for 2026 is calculable with precision before a single certificate is purchased.
From 2027 onward, the weekly pricing creates more variability. An authorized declarant importing steadily throughout the year buys certificates at different price points each week. Purchasing early in a low-price week reduces total cost; waiting risks buying at a higher weekly average. The CBAM certificates page covers the pricing mechanism in full detail, including how the Commission publishes weekly averages.
Step-by-Step: How to Buy CBAM Certificates from February 1, 2027
The certificate purchase process follows 6 steps. Each step requires prior completion of authorization and registry access as an authorized declarant.
Step 1: Confirm Your Authorized Declarant Status and Registry Access
Authorized declarant status is a prerequisite for certificate purchases. The authorization application deadline was March 31, 2026 under Article 17(7a) of Regulation (EU) 2023/956. As of January 2026, over 12,000 applications were submitted across EU member states. Declarants who applied by the deadline and remain under review retain provisional importing rights pending the NCA decision, which must be issued within 120 days of a complete application.
Registry access is granted automatically after authorization. Log into the EU CBAM Registry at cbam.ec.europa.eu using your UUM&DS credentials — the same authentication system used for EU ETS registry access.
Step 2: Calculate Your Quarterly Certificate Requirement
The quarterly holding requirement under Article 22(2) of Regulation (EU) 2023/956 requires that at the end of each calendar quarter, the authorized declarant holds at least 50% of the cumulative embedded emissions of all CBAM goods imported since the start of that calendar year.
The calculation proceeds as follows: sum all embedded emissions in tonnes CO₂e for CBAM goods imported since January 1 of the current year, then multiply by 0.5. The result is the minimum certificates required in your CBAM registry account by the last day of that quarter. The NCA issues a formal notice if this threshold is not met at the quarterly check date.
Example: By September 30, 2027, if an authorized declarant has imported BF-BOF steel carrying 800 tCO₂e in embedded emissions since January 1, 2027, the minimum holding is 400 certificates (800 × 50%).
Step 3: Access the Certificate Purchase Module in the CBAM Registry
From February 1, 2027, the Certificate Purchase Module is active within the EU CBAM Registry. Navigate to the purchase section of your CBAM account. The current weekly EU ETS auction closing price average is displayed in the module at the time of purchase. No NCA approval is required per transaction — the purchase is self-service within your account.
Step 4: Enter the Volume and Complete the Purchase
Enter the number of certificates to purchase. The total cost is calculated automatically as: number of certificates × current weekly average EU ETS closing price (for 2027+ imports) or the relevant 2026 quarterly average. Payment is made to the NCA by the method specified in your member state's national CBAM implementing rules.
The purchased certificates appear in your CBAM registry account immediately upon confirmed payment. They carry the year of purchase and remain valid until the November 1 cancellation date two years after the surrender year under Article 24(1) of Regulation (EU) 2023/956.
Step 5: Monitor Holdings Against the Quarterly Threshold
After purchase, track holdings against the quarterly 50% threshold throughout the year. The CBAM registry account displays current holdings, cumulative imported emissions (populated automatically from customs data feeds), and the calculated minimum threshold. Check this balance at least monthly to avoid approaching the deadline with a shortfall that requires a large purchase at the prevailing weekly price.
Step 6: Surrender Certificates at the Annual Declaration Deadline
The annual CBAM declaration deadline is September 30 each year, with the first declaration due September 30, 2027 covering calendar year 2026 imports. At the time of declaration, surrender the CBAM certificates equal to the total verified embedded emissions of all CBAM goods imported during the year, net of any Article 9 carbon price deductions. Certificates are cancelled in the registry upon surrender.
How Much to Budget: Certificate Costs by Sector at Current ETS Prices
Authorized declarants can estimate annual certificate costs using the embedded emission factors for each CBAM sector. The table below uses the current EU ETS reference price of approximately €70 per tonne CO₂ and the 2026 CBAM factor of 2.5% (reflecting 97.5% remaining free allocation under the ETS Directive).
| CBAM Sector | Emission Factor | Gross Cost per Tonne @ €70 | Net 2026 Cost per Tonne (2.5% factor) |
|---|---|---|---|
| Steel (blast furnace, BF-BOF) | ~2.0 tCO₂/t | ~€140 | ~€3.50 |
| Steel (electric arc, EAF scrap) | ~0.5 tCO₂/t | ~€35 | ~€0.88 |
| Cement (Portland) | ~0.83 tCO₂/t | ~€58 | ~€1.45 |
| Primary aluminium (direct only) | ~1.5 tCO₂/t | ~€105 | ~€2.63 |
| Urea fertilizer | ~2.5 tCO₂e/t | ~€175 | ~€4.38 |
| Grey hydrogen (SMR) | ~9–12 tCO₂/t | ~€630–840 | ~€15.75–21.00 |
Net 2026 costs are low because 97.5% of EU ETS free allocation remains available to EU domestic producers. The CBAM factor rises to 5% in 2027, 10% in 2028, and 48.5% by 2030 as free allocation phases out. Importers planning multi-year procurement and supply chain strategy should model certificate costs at 2028 and 2030 levels, not 2026 levels.
The Buyback Provision: Selling Excess Certificates Back to Your NCA
The buyback provision under Article 23 of Regulation (EU) 2023/956 allows authorized declarants to sell back up to 50% of CBAM certificates purchased in a given calendar year, at the original purchase price, no later than October 31 of the surrender year.
The 3 conditions for a valid buyback are listed below.
- The certificates to be returned must have been purchased in the same calendar year as the surrender year (not carried over from a prior year).
- The volume returned must not exceed 50% of the total certificates purchased in that year.
- The return must be submitted to the NCA by October 31 of the surrender year. Certificates not surrendered or returned by November 1 are cancelled without compensation under Article 24(1).
The buyback provision enables a strategic over-purchase approach. Authorized declarants can purchase up to twice their estimated annual requirement during periods of favorable weekly prices, then return the excess by October 31 after filing their annual declaration. The cost of the returned certificates is zero net of the refund.
CBAM Certificate Purchase vs EU ETS Allowance Purchase: Key Differences
CBAM certificates and EU ETS allowances are priced off the same EU ETS auction market, but they operate through entirely different channels. Authorized declarants already familiar with EU ETS should note 4 differences.
The 4 key differences between CBAM certificates and EU ETS allowances are as follows.
- Source of purchase: CBAM certificates are purchased only from the NCA of the authorized declarant's member state. EU ETS allowances are purchased on primary auction platforms (EEX, ICE) or the secondary market.
- Transferability: CBAM certificates cannot be transferred to another company or sold on any secondary market. EU ETS allowances are freely transferable.
- Banking: EU ETS allowances can be banked indefinitely. CBAM certificates are cancelled on November 1 of the year two years after the surrender year — limited shelf life.
- Price certainty: EU ETS allowances can be purchased at a known spot price at any time. CBAM certificate prices update only weekly (from 2027) or quarterly (for 2026 imports).
Caption: Unlike EU ETS allowances, CBAM certificates have no secondary market and are purchased directly from national competent authorities.
When CBAM Certificate Purchases Intersect with Importer Compliance Obligations
Certificate purchase is step 7 in the broader authorized declarant compliance chain. Purchases cannot be made before February 1, 2027, and the amount to purchase depends on having completed steps 1 through 6: applicability determination, authorization, registry access, import classification, emissions data collection, and third-party verification (for actual values rather than default values).
For the full compliance workflow including authorization, emissions verification, and the annual declaration process, see CBAM compliance for importers.
The EU ETS and CBAM certificate prices page tracks the weekly EU ETS auction clearing prices and the resulting CBAM certificate price as published by the Commission under IR (EU) 2025/2548.
The quarterly holding requirement and the October 31 buyback deadline create 2 hard cash-flow dates each quarter. Authorized declarants managing treasury exposure to EU ETS price movements can use the buyback provision as a partial hedge: over-purchase at a low weekly average, then sell back what is not needed by October 31 if prices rose. This limits upside cost exposure without introducing downside risk, since the buyback price equals the purchase price.
Frequently Asked Questions About Buying CBAM Certificates
When can I buy CBAM certificates?
CBAM certificate sales open on February 1, 2027, via the Common Central Platform operated by national competent authorities. No certificate purchases are possible before this date. Importers covering 2026 calendar year emissions purchase their certificates in 2027 at the retroactively known 2026 quarterly EU ETS auction averages.
Where do I buy CBAM certificates?
CBAM certificates are purchased exclusively from the national competent authority of the EU member state where the authorized declarant is established. The purchase is made through the Certificate Purchase Module of the EU CBAM Registry at cbam.ec.europa.eu. No secondary market, broker, or exchange trading exists for CBAM certificates.
How is the CBAM certificate price calculated?
For 2026 imports, the price equals the arithmetic average of EU ETS auction clearing prices for each calendar quarter during which the imports occurred, as set out in Article 22(1a) of Regulation (EU) 2023/956 and IR (EU) 2025/2548. From 2027, the price equals the weekly average of EU ETS auction closing prices, updated each week by the Commission.
Can I sell CBAM certificates back if I bought too many?
Authorized declarants can sell back up to 50% of certificates purchased in a given calendar year, at the original purchase price, by October 31 of that surrender year under Article 23 of Regulation (EU) 2023/956. Certificates not surrendered or returned are cancelled on November 1 without compensation.
Do I need to hold CBAM certificates throughout the year?
The quarterly holding requirement under Article 22(2) requires that at each quarter-end, an authorized declarant holds at least 50% of the cumulative embedded emissions of all CBAM goods imported since the start of that calendar year. Failing the quarterly threshold triggers a formal NCA notice and potential penalty exposure.
Is there a penalty for not buying enough CBAM certificates?
Authorized declarants who fail to surrender sufficient certificates at the September 30 annual declaration deadline face a penalty of €100 per tonne CO₂e not covered, under Article 26(1) of Regulation (EU) 2023/956 as amended. Unauthorized importers (those without authorization) face penalties of €300 to €500 per tonne CO₂e.
Does buying CBAM certificates reduce my EU ETS obligation?
CBAM certificates are a separate obligation from EU ETS allowances. EU importers do not participate in the EU ETS as regulated installations — that obligation applies to EU producers. CBAM certificates apply to the embedded emissions of imported goods. The two systems are price-linked but legally independent. See the CBAM declaration page for how certificate surrender interacts with the annual declaration.