European industrial buyers are increasingly evaluating imported steel, aluminium and other CBAM-covered goods using total delivered cost rather than headline supplier prices. Under the EU Carbon Border Adjustment Mechanism (CBAM), a variable carbon-related obligation is added to other expenses, including freight, customs duties and financing.
The CBAM calculation begins with the correct customs classification and country of origin. Buyers then incorporate purchase prices, logistics costs, applicable steel import quotas or tariffs, eligible embedded emissions, benchmark-based deductions and recognised carbon prices paid abroad. The legal responsibility to account for CBAM certificates lies with the authorised EU declarant, though contracts may shift the associated commercial costs to exporters or intermediaries.
CBAM certificate reference prices and embedded emissions calculations
The latest observable reference price for CBAM certificates is €82.32 per tonne of CO₂ equivalent for the third quarter of 2026, up from €75.28 in the second quarter. The reference price is not a flat charge of €82.32 on every tonne of imported metal. The final liability depends on the product’s calculated embedded emissions and applicable deductions.
For illustration, if a shipment has a correctly calculated net certificate exposure equivalent to 0.5 tonnes of CO₂ per tonne of goods, the carbon cost at the third-quarter reference price would be €41.16 per tonne of goods. This example is illustrative and not an official emissions factor for a specific product or country of origin.
Supplier comparisons can change when one producer provides verified actual emissions data below applicable Commission default values. Such evidence may enable an exporter to compete more effectively against a nominally cheaper supplier whose emissions data are insufficient. Claims of low-carbon production cannot be treated as a confirmed cost advantage without supporting installation-level evidence.
CBAM timetable and cash-flow gaps for 2026 imports
CBAM obligations apply to imports made during 2026, while certificate purchasing begins in February 2027. The first CBAM declaration and certificate surrender are due by 30 September 2027.
This schedule creates a gap between importing goods and meeting the resulting financial obligations. Buyers may have resold products or completed projects before the final cash outflow occurs, so procurement teams need coordination with finance departments on cost accruals, guarantees and liquidity requirements.
Steel quota rules add scheduling risk alongside CBAM costs
The EU’s separate steel import quota measure adds another layer of commercial risk for affected steel products. Tariff-free import volumes are reduced to approximately 18.3 million tonnes, and imports exceeding the applicable quota face a 50% duty.
With quota entitlement becoming critical, shipment scheduling can affect landed costs for steel covered by these rules. A supplier discount that appears attractive at quotation stage can be reduced by customs restrictions and additional border costs.
Contract terms for emissions data, verification and cost allocation
Procurement contracts are expected to specify who provides installation-level emissions data and which verification standards are acceptable. Contracts should also address how carbon-related costs are allocated across delivery quarters and how errors in emissions information will be corrected.
Where contractual arrangements allow, buyers can use verified emissions performance to support longer-term volume commitments and more predictable supplier relationships instead of relying exclusively on spot-price discounts. In such cases, emissions evidence becomes relevant both to commercial negotiations and regulatory compliance.
Emissions information is increasingly treated as an input into supplier selection, pricing and financial planning under CBAM, rather than only as documentation collected after a shipment arrives. This shifts procurement requirements toward calculating carbon-adjusted delivered cost before placing orders.