EU carbon border charge is in force, but certificates are sold from February 2027

The EU Carbon Border Adjustment Mechanism entered its definitive regime on 1 January 2026, after a transitional phase from 2023 to 2025. According to the European Commission, importers of selected goods must be authorised, must report their imports, and must buy and surrender CBAM certificates that match the emissions embedded in those imports.

The legal start and the payment start are not the same date. Certificate sales open in February 2027, so 2026 imports fall under the regime now but their certificates are bought later. The sections below cover scope, threshold, pricing, timetable and the points where the sources differ.

Which goods and importers are covered

The Commission's regime page lists six sectors: iron and steel, cement, aluminium, fertilisers, electricity and hydrogen. The scheme applies to imports of goods in these sectors, not to all trade with the EU. The pages read for this article list sectors but not product codes.

The Commission's main CBAM page calls the scheme the EU's tool to address carbon leakage, complementing the EU Emissions Trading System, or EU ETS. It aims to make the price of imports reflect their embedded emissions.

The obligation sits with the importer. The regime page says EU importers, or their indirect customs representatives, must seek authorisation once they pass the threshold. The sources reviewed do not name the overseas producer as a party that files or pays. They also do not say how contracts between EU buyers and overseas suppliers divide the cost.

The 50-tonne threshold, authorisation and verification

Importers that bring more than 50 tonnes of CBAM goods into the EU in a year must apply to become authorised CBAM declarants. The Commission describes this as a single mass-based threshold. Finnish customs, which relays Commission guidance, confirms that the 50 tonnes are counted per calendar year.

Guidance on applying is published under the Commission's Authorisation Management Module. Finnish customs, in a page dated 2 April 2025, says the Commission recommends that importers expecting at least 50 tonnes apply as soon as possible. Importers below that level are advised to wait until early autumn. The regime page, by contrast, encourages importers of CBAM goods to submit applications, without mentioning the threshold. The Finnish page describes the threshold guidance as a Commission recommendation.

Verifiers are a separate step, and the Commission's regime page does not describe their role. According to the Irish Environmental Protection Agency, verifiers apply to a national accreditation body. Those in the EU or EEA should apply to the body in their own country, or to another if their country does not offer CBAM accreditation. Verifiers from outside the EU may apply to any body that offers the service.

Accredited verifiers must apply to register in the CBAM Registry within two months of accreditation. The EPA says this applies from 1 September 2026, through the competent authority of the Member State where the accrediting body is based. The EPA also says the Commission will publish a list of accredited verifiers following accreditation of the first CBAM verifiers, which the EPA places in Q3 2026.

How the certificate price tracks the EU carbon market

The certificate price is based on the auction prices of EU ETS allowances, expressed per tonne of CO2 emitted. The Commission's price page describes it as a weighted average of the auction clearing prices of the allowances. For 2026 it is a quarterly average, with one price for each calendar quarter, calculated in the first calendar week after the quarter ends. From 2027 the Commission will calculate and publish it weekly.

The first 2026 price, €75.36, was published on 7 April. The Q2 price, €75.28, followed on 6 July. The Q3 price was published on 5 October at €82.32. SteelOrbis reports that this is a rise of €7.04, or 9.4%, on Q2. Its report is dated 6 October 2026 and does not give the Commission's publication date.

The Commission's price page says each 2026 quarterly price applies to certificates for emissions from CBAM goods imported in that quarter.

The Q4 2026 price is due on 4 January 2027, according to the Commission's price page. The EPA's table lists the Q4 publication date as 4 January 2026, which falls before the quarter it covers, so the year in that table appears to be an error. The EPA table leaves the Q4 price blank.

Certificate sales, holdings and surrender dates

Certificate purchases open in February 2027. The Irish EPA says they run on the Common Central Platform, which links to the CBAM Registry. The Commission's price page says all CBAM certificates will be bought on that platform from February 2027 onwards.

The Commission's regime page describes a different route. It says authorised declarants buy certificates from the National Competent Authority in the country where they are established, and surrender the corresponding certificates annually. The sources do not reconcile these descriptions, and this article reports both.

From 2027, declarants above the annual threshold must buy, by the end of each quarter, a minimum number of certificates covering at least 50% of the emissions embedded in goods imported since the start of the year. Certificates for 2026 emissions must be surrendered before 30 September 2027, according to the EPA.

The regime page says access to the CBAM Registry can be requested through the National Competent Authority of the Member State where the importer is established. Neither the regime page nor the main CBAM page gives a sales or surrender date. The February 2027 purchase start also appears on the price page; the 30 September 2027 surrender date comes only from the EPA.

The dated items in these sources are the quarterly and then weekly price publications, the February 2027 opening of purchases and the 30 September 2027 surrender deadline for 2026 emissions.

The free allowance phase-out and how the scope was set

Free allowances under the EU ETS for CBAM sectors are being phased out on a fixed schedule. Reed Smith sets out the agreed percentages as 2.5% in 2026, 5% in 2027, 10% in 2028, 22.5% in 2029, 48.5% in 2030, 61% in 2031, 73.5% in 2032, 86% in 2033 and 100% in 2034. Its alert gives the end of the transition period as 31 December 2025.

Reed Smith describes the timeline as a compromise among the Commission, the Council and the Parliament. Reed Smith dates the co-legislators' agreement on the final text to 13 December 2022. The Council had supported a complete phase-out by 2035, and the Parliament had advocated one by 2032. The agreed outcome is a complete phase-out by 2034. This article draws on a 2023 client alert for these figures and did not check them against the Official Journal text of the regulation.

The Commission first proposed cement, fertilisers, iron and steel, aluminium and electricity. The agreement added hydrogen, certain precursors and some downstream products, such as screws and bolts. Reed Smith also says the Commission will assess whether to extend the scheme to other goods at risk of carbon leakage, including organic chemicals and plastics, with the goal of covering all EU ETS goods by 2030. The 2023 alert does not report on that assessment.

Where the sources disagree or leave gaps

The EPA gives 30 September 2027 for surrendering certificates for 2026 emissions. None of the other listed sources gives a surrender date.

Two other points differ across pages. The Commission's regime page and the EPA describe the certificate purchase route differently, as set out above. The EPA table gives the Q4 2026 publication date as 4 January 2026, while the Commission's price page gives 4 January 2027.

The dates and percentages above rest on the Commission, EPA, Finnish customs and Reed Smith pages, and on the Commission price page and SteelOrbis for the quarterly prices.