The European Commission has published a draft Delegated Regulation setting out how the sale and repurchase of CBAM certificates could operate through the new Common Central Platform.

Published on 9 July 2026, the draft provides further detail on the proposed purchasing, payment, account-management and repurchase processes that will support the financial side of the EU Carbon Border Adjustment Mechanism.

The draft remains subject to change and is open for stakeholder feedback until 6 August 2026. It should therefore be treated as a proposed operational framework rather than final, adopted law.

For EU importers of iron and steel, aluminium, cement, fertilizers, hydrogen, electricity and other goods covered by the relevant CBAM commodity codes, the development is significant.

CBAM is no longer only about calculating and reporting embedded emissions. Businesses must also prepare to purchase and surrender certificates representing the carbon emissions associated with covered imports.

What Are CBAM Certificates?

A CBAM certificate is an electronic certificate corresponding to one tons of carbon dioxide equivalent, or CO₂e, embedded in imported goods.

Authorized CBAM declarants will use these certificates to meet their annual CBAM obligations. The number of certificates ultimately surrendered will be based on the embedded emissions declared for the relevant import year, after applying:

• any permitted reduction for a carbon price effectively paid in the country of origin; and
• the adjustment reflecting the extent to which EU producers continue to receive free EU ETS allowances.

CBAM certificates are designed specifically for compliance with the CBAM Regulation. Unlike EU ETS allowances, they will not be freely traded between companies on an open carbon market.

What Is the Current CBAM Certificate Price?

The CBAM certificate price is linked to the price of allowances under the EU Emissions Trading System.

For 2026, the European Commission calculates a separate certificate price for each calendar quarter using the weighted average auction clearing price of EU ETS allowances.

The official prices published so far are:

Each quarterly 2026 price applies to certificates associated with emissions embedded in goods imported during that quarter.

From 2027 onwards, the Commission will calculate and publish CBAM certificate prices weekly rather than quarterly.

When Will Businesses Start Buying CBAM Certificates?

Although the definitive CBAM regime began on 1 January 2026, authorized CBAM declarants will not begin purchasing certificates until 1 February 2027.

The certificates first purchased in 2027 will cover emissions associated with CBAM goods imported during 2026.

This timing is important for financial planning. Businesses are already accumulating a potential CBAM liability during 2026, even though the corresponding certificates cannot yet be purchased.

Who Can Purchase CBAM Certificates?

Only an authorized CBAM declarant will be able to purchase CBAM certificates.

Depending on the circumstances, the authorized declarant may be:

• an EU-established importer; or
• an indirect customs representative that has agreed to act as the authorized CBAM declarant.

Importers affected by CBAM should therefore confirm who will hold the authorized declarant status and who will be responsible for declarations, certificate purchases and surrender obligations.

Businesses should not assume that a freight forwarder or customs agent will automatically take responsibility for CBAM. The role and legal responsibility must be established clearly.

How Will CBAM Certificate Purchases Work?

1. Purchase Through the Common Central Platform

From 1 February 2027, EU Member States will sell CBAM certificates to authorized CBAM declarants established in their territory through the Common Central Platform.

The European Commission is responsible for establishing and managing the platform, but legally the certificates are sold by the relevant Member State.

This is an important distinction: businesses will not be purchasing freely tradable certificates from an exchange, broker or another importer.

2. Submit a Purchase Request

Under the Commission’s draft operational rules, the authorized CBAM declarant would initiate a purchase request through the CBAM system.

The Common Central Platform would process the corresponding payment, while the transaction and certificate information would be reflected in the declarant’s account in the CBAM Registry.

Because these detailed procedures are still contained in a draft Delegated Regulation, the final purchasing instructions may change before the system becomes operational.

3. Pay in Euros

The draft proposes that CBAM certificate prices be registered in euros and that payments connected with their sale and repurchase also be made in euros.

This is intended to provide consistency across Member States and avoid gains or losses arising solely from exchange-rate movements between purchase and repurchase.

4. Hold Certificates in the CBAM Registry

Once purchased and credited, CBAM certificates will be held in the authorized declarant’s account in the CBAM Registry.

The Registry will be used to manage the declarant’s certificates and complete the annual surrender process.

CBAM certificates should therefore be treated as a controlled compliance asset rather than a conventional investment or freely tradable carbon allowance.

When Must CBAM Certificates Be Surrendered?

Authorized CBAM declarants must submit an annual CBAM declaration and surrender the corresponding number of certificates by 30 September each year.

The first deadline is:

30 September 2027 for goods imported during 2026.

The final number of certificates to surrender will correspond to the declared embedded emissions after accounting for:

• the carbon price effectively paid in the country of origin, where the relevant conditions and evidence requirements are satisfied; and
• the adjustment reflecting free EU ETS allocation.

Businesses using actual emissions data must ensure that the data has been verified by an appropriately accredited independent verifier. Alternatively, declarations may use applicable default values made available under the CBAM framework.

The 50% Quarterly Certificate Requirement

A separate certificate-holding obligation applies from 2027.

At the end of each quarter, an authorized CBAM declarant must generally ensure that the number of certificates in its Registry account corresponds to at least 50% of the relevant embedded emissions in goods imported since the beginning of that calendar year.

The calculation may use the prescribed default-value or previous-year reference methods and must account for the adjustment relating to free EU ETS allocation.

This requirement is separate from the annual declaration and surrender deadline. It means businesses may need to purchase certificates throughout the year rather than waiting until September to buy their entire annual requirement.

Can Surplus CBAM Certificates Be Repurchased?

Yes, but repurchase is subject to legal conditions and quantity limits.

After completing the annual surrender process, an authorized CBAM declarant may request the repurchase of eligible excess certificates remaining in its Registry account.

The Commission will process the repurchase through the Common Central Platform on behalf of the Member State in which the authorized declarant is established.

The repurchase request must be submitted by 31 October of the year in which the certificates were surrendered.

How Is the Repurchase Price Calculated?

An eligible CBAM certificate is repurchased at the same price paid for that individual certificate at the time of purchase.

This means the repurchase arrangement is not intended to create a trading profit or allow businesses to speculate on movements in EU ETS prices.

Are There Limits on Repurchase?

Yes.

Under the amended CBAM Regulation, the number of certificates eligible for repurchase is generally limited to the total number the authorized declarant was required to purchase under the quarterly certificate-holding obligation during the relevant calendar year.

A special provision also applies where a business purchased certificates because it expected to exceed the annual 50-tonne threshold but did not ultimately exceed it.

Certificates purchased in 2027 for emissions associated with 2026 imports may only be repurchased during 2027.

What Does the Draft Regulation Propose?

The July 2026 draft proposes that:

• a declarant may normally submit one repurchase request each year;
• the request cannot be amended or withdrawn after submission;
• the request must concern at least one whole certificate;
• the declarant must have completed its required annual surrender; and
• the competent authority must approve the request before payment is completed.

These details remain draft proposals until the Delegated Regulation is formally adopted.

What Happens to Unused CBAM Certificates?

Businesses should not assume that certificates can remain in their accounts indefinitely.

Under the CBAM Regulation, older certificates remaining in an authorized declarant’s account may be cancelled without compensation.

There is a specific rule for the first compliance cycle: on 1 November 2027, certificates purchased in relation to embedded emissions from 2026 will be cancelled if they remain in the account after the applicable surrender and repurchase processes.

Where the required surrender amount is subject to an ongoing legal dispute, cancellation must be suspended to the extent of the disputed number of certificates.

CBAM Certificate Cost Example

Consider an EU company importing goods during Q1 2026 with 2,000 tonnes of declared embedded CO₂e emissions before the applicable CBAM reductions and adjustments.

The official Q1 2026 CBAM certificate price is €75.36.

For initial budgeting purposes:

2,000 × €75.36 = €150,720

However, €150,720 should not automatically be described as the company’s final CBAM cost.

The final number of certificates required may be lower after accounting for:

• the adjustment reflecting free EU ETS allocation;
• an eligible carbon price effectively paid in the country of origin; and
• any correction to the embedded emissions calculation.

The example is therefore a gross budgeting illustration, not a final legal-liability calculation.

Which Businesses Are Affected by CBAM?

CBAM currently covers specified goods within the following sectors:

• iron and steel;
• aluminium;
• cement;
• fertilisers;
• hydrogen; and
• electricity.

Coverage depends on the goods’ Combined Nomenclature, or CN, codes. Not every product containing steel, aluminium or another CBAM material is automatically covered unless its commodity code falls within the relevant scope of the Regulation.

Businesses should therefore review their customs classifications rather than relying only on general product descriptions.

Does the 50-Tonne CBAM Threshold Apply to Every Sector?

No.

The annual 50-tonne net-mass threshold applies cumulatively across covered goods in the following four sectors:

• iron and steel;
• aluminium;
• cement; and
• fertilisers.

Where an importer exceeds the threshold during the calendar year, its CBAM obligations apply to all relevant covered imports made during that year, including the goods imported before the threshold was exceeded.

The mass-based exemption does not apply to imports of electricity or hydrogen.

Why CBAM Certificates Matter for Financial Planning

CBAM introduces a direct and potentially significant financial commitment for affected importers.

The consequences extend beyond sustainability and customs reporting. Businesses may need to consider:

• carbon-cost budgeting;
• working-capital requirements;
• certificate purchasing schedules;
• supplier emissions data;
• procurement decisions;
• the reliability of commodity classifications;
• carbon prices paid outside the EU;
• product pricing and margins;
• audit and verification costs; and
• governance between finance, customs, procurement and sustainability teams.

Importers will accumulate potential CBAM exposure throughout the year, while certificate prices may change from one pricing period to another.

Weak emissions forecasts could result in insufficient certificate holdings and compliance exposure. Excessive purchasing could tie up working capital and leave the business dependent on the restricted repurchase process.

What Should EU Importers Do Now?

Confirm Whether Imported Goods Are in Scope

Review the CN codes used for imported goods and confirm whether they appear within the relevant CBAM annex.

Do not rely solely on commercial product descriptions or the material from which a product is made.

Review the 50-Tonne Threshold

Calculate the cumulative annual net mass of covered iron and steel, aluminium, cement and fertiliser imports.

Remember that hydrogen and electricity are not covered by the 50-tonne exemption.

Confirm the Authorized CBAM Declarant

Establish whether the importer or an indirect customs representative will act as the authorized CBAM declarant.

Responsibilities for declarations, supplier data, certificate purchases and surrender should be documented clearly.

Improve Supplier Emissions Data

Engage with non-EU suppliers to determine whether reliable actual emissions data can be provided.

Where actual values are used, the data must satisfy the CBAM calculation rules and be verified by an accredited verifier. Where that is not possible, applicable default values may need to be used.

Build a CBAM Financial Forecast

Model potential exposure using:

• expected import volumes;
• relevant quarterly or weekly certificate prices;
• actual or default embedded emissions;
• the applicable free-allocation adjustment; and
• any eligible carbon-price deduction.

Forecasts should distinguish between gross indicative exposure and the final number of certificates legally required.

Create an Internal Certificate Calendar

Businesses should record the different stages separately:

• certificate price publication;
• certificate purchases;
• quarterly account-holding requirements;
• annual declaration;
• annual surrender;
• repurchase deadline; and
• cancellation date.

Treating these as one general “CBAM deadline” creates unnecessary compliance risk.

Key CBAM Certificate Dates

Frequently Asked Questions About CBAM Certificates

Can CBAM certificates be bought in 2026?

No. Certificate prices are being calculated and published during 2026, but purchases through the Common Central Platform will begin on 1 February 2027.

The first certificates purchased will cover emissions associated with goods imported during 2026.

Can businesses trade CBAM certificates with each other?

No. CBAM certificates are compliance instruments and are not intended to operate as freely tradable allowances between businesses.

Eligible surplus certificates may instead be repurchased through the official mechanism, subject to the conditions and limits in the CBAM Regulation.

Is one CBAM certificate equal to one tonne of imported goods?

No. One certificate corresponds to one tons of CO₂e embedded emissions, not one tonne of imported goods.

The emissions intensity of the product determines how many tons of CO₂e are associated with a given quantity of imports.

Will every importer need to buy CBAM certificates?

Not necessarily.

Importers whose annual covered imports remain within the applicable 50-tonne exemption may not be subject to the standard CBAM obligations for that year. However, the threshold only applies to covered iron and steel, aluminium, cement and fertiliser goods.

It does not apply to electricity or hydrogen.

Is the certificate price the same as the final CBAM cost?

No.

The published certificate price is one part of the calculation. The final number of certificates required also depends on embedded emissions, the free-allocation adjustment and any eligible carbon price paid in the country of origin.

CBAM Is Becoming a Financial and Operational Priority

The publication of the draft sale and repurchase rules marks another important step in the implementation of the EU CBAM system.

For affected importers, the priority is no longer limited to reporting carbon emissions. Businesses must also prepare to forecast certificate requirements, fund purchases, maintain sufficient account balances and complete annual surrender obligations.

The detailed platform procedures remain in draft form and may change before adoption. However, the core direction is clear: CBAM must now be managed as a combined customs, emissions, financial and governance responsibility.

Organisations that begin preparing early will be better positioned to control costs, improve supplier data and reduce the risk of unexpected CBAM exposure.

Prepare Your Business for CBAM

Allied Group’s certified CBAM training helps businesses understand their obligations and prepare for the practical and financial requirements of the definitive CBAM regime.

The programme covers:

• CBAM scope and commodity classification;
• authorized CBAM declarant requirements;
• embedded emissions and supplier data;
• actual and default emissions values;
• CBAM certificate pricing;
• budgeting and financial forecasting;
• annual declaration and surrender requirements;
• common compliance risks; and
• practical steps for managing CBAM internally

Register for the next Allied Group CBAM training programme and ensure your business is prepared for the financial and operational requirements ahead.

CLICK HERE FOR REGISTRATION

This article reflects the EU CBAM framework and the Commission draft available as of 21 July 2026. The July 2026 Delegated Regulation remains in draft form and may be amended before final adoption. This article provides general information and should not be treated as legal, tax or financial advice.