Companies importing goods covered by the Carbon Border Adjustment Mechanism (CBAM) in 2026 will be subject to four quarterly certificate prices rather than a single annual carbon price. The European Commission is assigning a separate price to each quarter of import, creating four distinct carbon-cost vintages within the first year of the definitive regime. The approach affects margin analysis, supplier comparisons, financial provisioning and year-end reporting.
The published certificate prices are €75.36 per tonne of CO₂ for the first quarter, €75.28 for the second and €82.32 for the third quarter. The fourth-quarter price is scheduled for publication on 4 January 2027. For 2026 imports, certificate requirements are calculated from embedded emissions by quarter, with the corresponding quarterly price applied when certificates become available for purchase in 2027.
Quarterly certificate pricing links carbon costs to import dates
The quarterly pricing structure means that importers with stable physical volumes can still see changes in carbon costs as deliveries fall into different pricing periods. Goods arriving in a higher-price quarter can lead to higher certificate costs even when product specifications and emissions intensity remain unchanged.
Procurement and finance teams may also need to account for supplier switching effects. Using a supplier with lower verified embedded emissions can offset part of an increase driven by the EU carbon market, but only if import dates and corresponding emissions data are kept together rather than averaged across the year.
Exposure from 2026 imports is accumulating even though the first annual CBAM declaration and certificate-surrender deadline is 30 September 2027. Management reporting is expected to maintain a live link between physical imports, estimated certificate requirements and anticipated cash outflows, rather than relying only on a year-end sustainability report.
Provisional emissions assumptions before verification and surrender
CBAM introduces different timelines for imports, emissions verification and certificate pricing. Goods may enter the EU before verified actual emissions data are available, while the applicable certificate price follows the quarterly schedule.
Companies therefore need a provisional emissions assumption and an update process once verified data are received. Recognising exposure only after final verification could result in substantial historical costs being identified after customer prices have already been agreed.
A disciplined accrual process is described as a way to recognise expected liabilities while clearly marking assumptions that remain provisional. A control file is also expected to support a quarter-by-quarter reconciliation from customs entries to covered quantities, specific embedded emissions, any free-allocation adjustment, eligible deductions for carbon prices paid abroad and the relevant certificate price.
Implications for contracts when EU ETS prices move
The quarterly mechanism can affect commercial agreements, including cases where a fixed CBAM surcharge is agreed at the beginning of the year. Unexpected gains or losses may arise if EU ETS prices change or if verified emissions differ from initial estimates.
More robust contract structures can specify a calculation formula tied to official certificate prices and agreed emissions data, followed by adjustment after verification is complete. The agreement should distinguish provisional information from verified values and define which changes trigger a price true-up.
An example described involves an initial estimated emissions intensity provided by a supplier, followed later by an accredited verification report. At the same time, the official certificate price may change between contract negotiation and settlement, making defined adjustment mechanisms relevant for dispute reduction and cost estimation without waiting for all compliance inputs to be final.
Approaches for exporters in Serbia and the wider Western Balkans
Exporters in Serbia and other parts of the Western Balkans can apply the same approach when preparing offers for EU customers. Instead of quoting a generic CBAM premium, they can show how product verified emissions intensity affects estimated certificate quantity while treating the official EU certificate price as an external market variable.
This distinction is intended to help buyers separate components of potential cost linked to supplier performance from those linked to the carbon market. It can also support more consistent supplier comparisons when products arrive in different quarters or use different emissions assumptions.
Finance teams are described as maintaining separate quarterly cost records for 2026 rather than using a single annual proxy before final calculation requirements are met. Contracts covering late-year deliveries should specify how the relevant import quarter is determined and how subsequent emissions corrections or other adjustments are handled.
Connecting customs entries with procurement and finance records
A practical implementation test is whether a company can explain its calculation to both an auditor and a commercial manager using the same underlying records. CBAM documentation should connect purchasing, production, customs and finance rather than operate as a separate compliance file.
The described minimum decision file links customs volumes, the emissions basis, certificate prices, expected cash timing and contractual cost pass-through while identifying who approves each assumption. Routine operational data, controlled assumptions and documented fallback methods are used to reflect changes in suppliers, transport routes, prices or legal requirements without rebuilding the calculation.
A fallback should also be documented where preferred emissions treatment cannot be substantiated. Although that alternative may be commercially less favourable, defining it early reduces the risk of discovering actual exposure only after challenges by a verifier, customs authority or authorised declarant.
Consistent records are described as making later price adjustments, verification changes and management reporting easier to defend. With four quarterly certificate prices in place for 2026 imports, import quarter selection becomes an important variable in carbon-cost and invoice economics.