The feedback period on the draft delegated regulation for the sale and repurchase of CBAM certificates closed on August 6, 2026 with a final count of 93 submissions. The last response was timestamped 23:57, three minutes before the midnight deadline. The consultation, Have Your Say initiative 14132, opened on July 9 and ran for four weeks. It covers the rules under which authorized CBAM declarants will buy certificates from February 1, 2027.
The closing count matters for every importer of steel, cement, aluminium, fertilizers, electricity, and hydrogen, because the contested provisions govern how their money moves: how purchase requests are filed, how excess certificates are sold back, and what a request error costs. The record stood at 65 submissions on August 5, which means 28 responses, roughly 30 percent of the total, arrived between that count and the midnight close.
Who filed in the final 48 hours
The final-day filers span national business chambers, EU-level trade associations, energy and steel companies, and third-country governments, with more than 20 submissions timestamped on August 6 alone. The Commission's feedback API confirms the names and timestamps. Wirtschaftskammer Österreich filed at 16:55, Danish Industry at 23:13, and the last submission of the entire consultation arrived at 23:57 from a respondent in Serbia.
The table below lists notable submitters recorded on the closing day, based on the published feedback data.
| Submitter | Profile | Country |
|---|---|---|
| Wirtschaftskammer Österreich | National business chamber | Austria |
| Danish Industry | Industry federation | Denmark |
| VDMA | Mechanical engineering association | Belgium (EU office) |
| CLECAT | Freight forwarders and customs agents | Belgium |
| ORLEN SA | Energy group | Poland |
| Duferco International Trading | Steel trader | Luxembourg |
| KOSA | Steel association | South Korea |
| Çolakoğlu Metalurji | Steel producer | Turkey |
| Medcem Cement | Cement producer | Turkey |
| SEFE Marketing and Trading | Energy trader | United Kingdom |
| Brazil Steel Institute | Steel association | Brazil |
| Hungarian Chamber of Agriculture | Agricultural chamber | Hungary |
Other late filers include the European Fastener Distributor Association, Employers of Poland, the chemical distributors' federation FECC, the Dutch fastener importers' association NEVIB, and Brazil's Finance and Development ministries, which submitted alongside the country's steel industry.
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Why third countries filed at the wire
Government bodies and industry groups from Brazil, Turkey, Korea, Japan, Taiwan, Serbia, Thailand, and Cambodia filed feedback, and that breadth signals three design choices in the draft are contested internationally. Exporting countries do not buy certificates themselves, but their producers absorb the friction their EU customers face, and several submissions treat the platform mechanics as a market access question rather than an administrative detail.
The three most contested mechanics across the submissions are listed below.
- The annual repurchase limit. The draft allows one repurchase request per year. Filers argue this locks working capital into certificates that cannot be converted back to cash for months.
- The 42-day processing window. Respondents question why an electronic system working from pre-verified registry data needs six weeks to process a request.
- The EUR 0.05 platform fee. Submissions describe the per-certificate fee as high compared with the fees charged by other electronic trading venues.
The Korean steel association KOSA filed on the closing day, consistent with the scale of what its members have at stake: Korean steel faces an estimated USD 4 billion CBAM exposure through 2030. For Turkish, Brazilian, and Southeast Asian exporters, every euro of platform friction lands on top of the certificate cost their EU buyers already price into contracts.
The Gerber Group's one-click trap critique
On August 7, 2026, one day after the consultation closed, the German stainless steel and aluminium trader Gerber Group called the draft an "irrevocable one-click trap" for SMEs. The critique, issued as a press release published via steelnews.biz, targets the absence of any correction mechanism in the draft. Purchase requests cannot be amended after submission. Repurchase requests can be filed once a year with no right of correction or withdrawal, even moments after submission. A typing error, on the company's reading, becomes a financial risk fixable only through court proceedings.
"A typing error is not fraud, legal action is not a correction function, and a single irrevocable request per year is not simplification," the company stated.
The Gerber Group, a mid-sized trader headquartered in Riegel am Kaiserstuhl, also priced the platform fee. By its estimate, EUR 0.05 per certificate is roughly 16 times the venue fees at EEX, the exchange that hosts EU ETS auctions, and would generate around EUR 22 million per year across the market. Its five demands are listed below.
- Grant a general right to correct obvious input errors before payment
- Process repurchase requests monthly, within 15 calendar days
- Protect deadlines automatically when Commission systems fail
- Provide support in the official languages of the Member States rather than an English-only helpline
- Involve SMEs in structured platform testing before the February 1, 2027 go-live
What the draft requires from importers
The draft delegated regulation requires authorized CBAM declarants to file purchase and repurchase requests in the CBAM Registry, in lots of 1 to 99,999 certificates per request, with euro payments settled through a common central platform. Certificates are non-transferable, so a purchase error cannot be traded away to another declarant; it can only be carried or sold back to the Member State under the repurchase rules.
The CBAM Registry is where requests originate, while settlement runs through the common central platform procured jointly by the Commission and Member States. How CBAM certificates are priced and surrendered is unchanged by this draft: it regulates the transaction layer, not the obligation. Importers planning their first purchases can walk through the certificate purchase process ahead of the sales opening.
What happens next
The initiative sits in interservice consultation, and adoption, originally foreseen for Q2 2026, has slipped to a planned Q4 2026. The Commission had published no statement on next steps as of August 15. The initiative page still listed second-quarter adoption when the feedback window closed, a date that had already passed before the consultation even opened on July 9.
The timeline pressure is real. Certificate sales begin February 1, 2027, and from that point importers must maintain the quarterly holding requirement of at least 50 percent of the cumulative embedded emissions of their imports. An adoption in Q4 2026 leaves the platform, its fee structure, and any correction rights to be finalized barely three months before declarants start clicking the buttons the Gerber Group warns about. Certificate budgeting is a separate track: the Q3 CBAM certificate price is tracking six to eight euros above Q2, so the cost of the certificates themselves is moving while the rules for buying them remain in draft.