CBAM Certificates: How to Buy Them, How the Registry Works, and the Link to EU ETS Prices

What CBAM Certificates Are#

CBAM certificates are the financial instrument through which importers of steel, aluminium, cement, fertilisers, electricity, and hydrogen pay for the carbon embedded in their imports. Each certificate represents one tonne of CO₂ equivalent. From January 2026, authorised CBAM declarants must hold sufficient certificates at all times to cover the embedded emissions of goods they have imported to date. By 31 May each year, they must surrender certificates equal to the total embedded emissions from the preceding calendar year's imports, as declared in their annual CBAM declaration. The certificate mechanism mirrors the EU ETS: EU manufacturers surrender free allowances or purchase ETS allowances to cover their emissions; CBAM importers purchase CBAM certificates at an equivalent price. The design intent is price equivalence — an imported tonne of steel should face the same carbon cost as a domestically produced tonne.

How Certificates Are Priced#

CBAM certificate prices are set weekly by the European Commission based on the average EU ETS allowance price in the previous week's carbon auctions. The Commission publishes the weekly CBAM certificate price on the CBAM Registry platform. This means CBAM costs are not fixed — they fluctuate with EU ETS prices. In 2023-24, EU ETS prices ranged from approximately €50 to €100 per tonne of CO₂, with the average around €60-65 during 2024. A steel importer with 10,000 tonnes of embedded CO₂ in annual imports would therefore face an approximate annual CBAM cost of €600,000-€650,000 at 2024 ETS price levels. ETS prices are expected to rise over time as free allowance allocations to EU producers phase out between 2026 and 2034, creating upward cost pressure on CBAM obligations for importers.

The CBAM Registry: How Purchasing Works#

Authorised CBAM declarants purchase certificates through the CBAM Registry, an EU platform operated by the European Commission. Access requires completing the CBAM declarant authorisation process with the national competent authority. Once authorised, declarants can buy certificates through the Registry at the current weekly price — there is no auction mechanism for CBAM certificates as there is for ETS allowances. The Registry tracks each declarant's certificate holdings and links them to their submitted CBAM declarations and due diligence information. Certificates can be purchased at any time during the year — there is no requirement to buy them all at once. This allows importers to time purchases based on their view of ETS price movements, though speculation is limited by the surrender obligation.

Surrender Obligations and Resale#

The annual surrender deadline is 31 May. By that date, CBAM declarants must surrender certificates equal to their annual embedded emissions, calculated from their verified CBAM declaration. If a declarant holds more certificates than required, they can request the competent authority to repurchase the excess — but at a discount of 25% to the purchase price. This 25% haircut on resale is deliberate: it discourages over-purchasing certificates and disincentivises using the CBAM Registry as a speculative instrument. Any carbon price paid in the country of origin can be deducted from the certificate requirement — if the exporter paid €20 per tonne under a home country carbon pricing scheme, the CBAM obligation reduces by €20 per tonne, with documentation required to prove the payment.

Strategic Implications for Importers#

CBAM certificates create a new ongoing cost line for importers in covered sectors from 2026. For some product categories — particularly lower-grade steel from high-emission production processes — CBAM could make EU market access uneconomical. For importers, the strategic options include: switching to lower-carbon suppliers (from countries with established carbon pricing, which generates deductible carbon price credits); sourcing from countries that may receive low-risk CBAM status; pursuing EU domestic sourcing alternatives; or absorbing the cost and passing it to customers. AskBiz calculates your estimated annual CBAM certificate cost based on your import volumes and the current EU ETS price, updated weekly, so you can model these strategic options with current data rather than stale estimates.

• From January 2026, importers of CBAM goods must purchase CBAM certificates through the CBAM Registry at a price linked to the weekly average EU ETS carbon price.
• Certificates must be surrendered by 31 May each year to cover embedded emissions from the preceding year's imports.
• Unsurrendered certificates may be sold back to the authority at a 25% discount.