The four-week feedback period on the draft delegated regulation governing CBAM certificate sales and repurchases closes on August 6, 2026, and the public record shows broad demand for changes. As of August 5, 2026, the Commission's Have Your Say portal listed 65 submissions on initiative 14132, with a heavy final wave filed between July 30 and August 5. The outcome concerns every authorized CBAM declarant in the EU, because the draft fixes how certificate purchases and repurchases will operate when sales open on February 1, 2027.
The draft, published for feedback on July 9, 2026 under Article 20(6) of Regulation (EU) 2023/956, routes purchase and repurchase requests of 1 to 99,999 certificates through the CBAM Registry, settles payments in euro via a common central platform, charges a fixed fee of €0.05 per certificate, keeps certificates non-transferable, and allows one repurchase request per declarant per year. Our earlier coverage of the certificate sale and repurchase consultation walks through those mechanics in detail. The Commission plans adoption in the fourth quarter of 2026. Until then, every rule in the draft remains a proposal, not adopted law.
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Who filed: carmakers, metal traders, steelmakers, and three Asian governments
As of August 5, 2026, the consultation had drawn 65 submissions, and the filings between July 30 and August 5 brought in some of the largest names on the record. The late wave spans manufacturers, trade associations, energy companies, and non-EU public bodies.
Notable submitters in the final week include the following groups.
- Manufacturers and importers: BMW AG, the Liebherr group, fastener maker Adolf Würth, and furniture fittings manufacturer Hettich
- European and international associations: ACEA (the European automobile manufacturers' association), IETA, EUROFER, the Business for CBAM Coalition, the Czech Chamber of Commerce, and the Japan Iron and Steel Federation
- German metals trade: the associations VDM (Verband Deutscher Metallhändler und Recycler), BDS, and WGM, plus trading companies INTERFER and alpha aluminium
- Energy and steel producers: Enel, Slovenia's HSE Group, and Hyundai Steel
- Governments and public bodies: Taiwan's Ministry of Environment and Ministry of Economic Affairs, and Thailand's Greenhouse Gas Management Organization
- Compliance service providers: carbon accounting platform CarbonChain
The breadth matters. A consultation on payment plumbing could have drawn a dozen technical filings. Instead, the record captured car manufacturers, three Asian government bodies, and the trade associations of an entire metals supply chain, filing within seven days of each other.
What the submissions demand, rule by rule
The filings converge on five demands: more frequent repurchase windows, faster processing, removal of the €0.05 fee, partial and group-level certificate management, and transitional flexibility before February 2027. No single demand appears in every submission, but each theme recurs across multiple filings in the record. The table below maps the draft rules to the changes requested and to examples of who requested them.
| Draft rule | What filers ask for | Raised by (examples) |
|---|---|---|
| One repurchase request per declarant per year | Monthly or quarterly repurchase windows | INTERFER, alpha aluminium, other metals-trade filings |
| Repurchase processing within a 42-day maximum | Cut to roughly 5 to 14 days; INTERFER asks for one working day | INTERFER and further industry filings |
| €0.05 fixed fee per certificate | Drop the fee or justify its basis | Czech Chamber of Commerce, among others |
| Full-request, per-declarant repurchase design | Partial repurchases and group-level certificate management | Multiple manufacturer and association filings |
| Application from February 1, 2027 | Transitional flexibility for the first sales period | Multiple filings across the record |
The repurchase window is the dominant theme. In its August 4 filing, German stainless steel trader INTERFER requests at least one repurchase opportunity per month and asks that the 42-day processing period shrink to one working day. Aluminium trader alpha aluminium, filing July 31, requests a rolling monthly buy-back mechanism, arguing that companies must not be forced to tie up capital on a massive scale without environmental benefit.
Why the annual repurchase limit draws the most fire
The single annual repurchase window collides with the quarterly holding requirement, which obliges declarants to hold certificates covering at least 50 percent of the cumulative embedded emissions of their imports at the end of each quarter. Cautious buyers will overshoot that floor rather than risk falling below it, so surpluses arise by design. Under the draft, a declarant carrying surplus certificates gets exactly one chance per year to sell them back, with no amendment and no correction path inside the cycle.
That design ties up working capital, and the capital at stake is growing. The Q2 2026 certificate price was €75.28/tCO₂e, and the Q3 certificate price is tracking well above Q2 as EU ETS allowances hold the €79 to €86 band. VDM, which represents roughly 235 metal trading and recycling companies, states in its August 5 filing that the system must be "operational, proportionate and economically viable." WGM, the German wholesale association for semi-finished metal products, asks for proportionate burdens on SMEs in its July 31 submission.
The €0.05 fee drew the sharpest legal framing. The Czech Chamber of Commerce argues in its July 30 filing that the per-certificate fee "functions in practice as a de facto tariff," with the burden "falling most heavily on large industrial exporters." The fee is small per certificate, roughly 0.07 percent at the Q2 price, but it is uncapped in aggregate: a maximum-size purchase request of 99,999 certificates generates a fee just under €5,000 on top of a transfer of about €7.5 million through the common central platform.
What can still change before Q4 adoption
The Commission evaluates the feedback after August 6, 2026, and plans to adopt the delegated regulation in the fourth quarter of 2026, so the consensus demands preview what may change in the final text. Feedback periods on delegated acts do not oblige the Commission to amend anything, but 65 submissions with recurring, specific asks give it a clear menu: repurchase frequency, processing speed, the fee, and partial repurchases are the four levers filers pushed hardest.
Two constraints shape what the Commission can concede. First, the delegated act must stay within the empowerment of Article 20(6) of Regulation (EU) 2023/956, so demands that touch the basic regulation, such as making CBAM certificates transferable, are outside its reach. Second, after adoption the act passes to the European Parliament and the Council, which can object before it enters into force. The timeline leaves little slack: the rules must be operational when certificate sales begin on February 1, 2027, and purchases from that date count toward the first annual declaration due September 30, 2027.
What importers should do while the rules are pending
The draft remains a proposal, but the February 1, 2027 start date does not move with it, so four preparation steps hold regardless of how the final text lands.
- Model your certificate volumes now. The guide on how to buy CBAM certificates covers the purchase workflow, and the CBAM cost calculator converts import volumes into certificate counts and euro amounts.
- Plan around the annual repurchase window as drafted. If the final act keeps one request per year, over-purchasing carries a real carrying cost, so buy against verified emissions data rather than rough estimates.
- Prepare the two-system workflow. Requests sit in the CBAM Registry while money moves through the central platform, and the draft requires same-day payment, so compliance and treasury teams need a joint process before the first purchase.
- Watch the Q4 adoption. Whether the Commission concedes monthly repurchase windows or a lower fee will be visible in the adopted text, and we will compare it against the draft when it publishes.
For the full compliance chain from authorization to certificate surrender, read the EU CBAM guide.