CBAM timeline and certificate prices: the 2026–2038 roadmap

The transitional period ran from 1 October 2023 to 31 December 2025 and is over. During that phase the only duty was reporting: importers declared embedded emissions and paid nothing. Since 1 January 2026 the definitive regime applies, and embedded emissions in covered goods now create a financial liability.

The application window for authorised declarant status closed on 31 March 2026. From 2027 two regimes run in parallel — the EU mechanism and the UK one — with different scopes, different thresholds and entirely different collection machinery.

On 1 February 2027. Not a single CBAM certificate can be bought during 2026. The liability accrued on 2026 imports is settled with certificates purchased in 2027, and the first annual declaration and surrender falls on 30 September 2027.

The pricing mechanism changes at the same moment. Through 2026 the certificate price is published quarterly, derived from the average price of EU ETS allowances. From 2027 it is set weekly — which turns purchase timing into a genuine treasury decision rather than a formality.

The first two quarters of the definitive regime came in almost identical, which gives a workable planning assumption for 2027 budgets: roughly €75 per tonne.

The gap between the two quarters is under a tenth of a percent. Do not project that stability forward: the price tracks EU ETS allowances, so every ETS movement passes through to certificate cost — and from 2027 it passes through weekly. Budget against a range, not a point estimate.

The UK built its mechanism through Finance Act 2026, Part 5, in force from 1 January 2027. The name is shared; the architecture is not. The UK CBAM is a tax collected by HMRC, not a certificate purchase-and-surrender system. There is nothing to buy, hold or redeem.

Glass and ceramics were dropped from the final UK scope and electricity is excluded altogether. In the other direction, the UK definition of indirect emissions is broader than the EU’s: heat, steam and cooling are captured alongside electricity. A producer selling into both markets therefore has to run two emissions calculations with two different boundaries for the same installation — and the UK rate, being sector-specific and quarterly, will not track the EU certificate price.

Regulation (EU) 2025/2083, the Omnibus simplification, exempts importers whose cumulative annual net mass does not exceed 50 tonnes. It covers iron and steel, aluminium, fertilisers and cement, but not electricity or hydrogen.

The Commission’s rationale is straightforward: the threshold takes roughly 90% of importers out of scope while keeping roughly 99% of embedded emissions inside it. If the threshold is crossed mid-year, the obligation applies retroactively from 1 January, so treating it as a year-end question is a mistake.

The definitive regime does not start at full liability. Regulation (EU) 2023/956 — the law currently in force — sets a CBAM factor for each year, and the number of certificates to be surrendered follows that percentage.

The inflection point is 2029 to 2030, where the factor jumps from 22.5% to 48.5% — more than doubling the liability in a single year. To size it: at 10,000 tCO₂e of embedded emissions and a flat €75 per tonne, the 2026 charge is around €18,750 and the 2030 charge around €363,750. Those figures are illustrative orders of magnitude; a documented carbon price already paid in the country of origin reduces them.

Where installation-specific data is not available, Commission default values apply. Implementing Regulation (EU) 2025/2621 adds a mark-up on top of them: +10% for 2026, +20% for 2027 and +30% from 2028 onwards, with an exceptional 1% for fertilisers.

This is one of the few places where the regulation prices data quality explicitly. From 2028, a producer with a verified installation-level calculation can be declared at an embedded emissions figure roughly thirty percent below a competitor relying on defaults for the same product — a difference that lands directly in landed cost.

Proposal — not law

On 17 July 2026 the Commission published COM(2026) 616, its proposal for revising the EU ETS. It slows the CBAM phase-in and pushes full liability from 2034 to 2038. Nothing in it applies until it clears the Council and the European Parliament; the binding text for planning purposes remains Regulation (EU) 2023/956.

The 2026 (2.5%) and 2027 (5%) factors are untouched by the proposal, so near-term planning is unaffected either way. If it is adopted, cost forecasts for 2028 to 2037 need revisiting. Keeping both columns in your model now is cheaper than rebuilding the forecast in 2027.

For anyone sourcing from Türkiye, the relevant development is Climate Law No. 7552, published in the Official Gazette on 9 July 2025 (issue 32951), which establishes a national emissions trading system and a Carbon Market Board. The ETS regulation is still in draft: the structure envisaged is a 2026–2027 pilot, a first compliance period from 2028 to 2035, and coverage of installations above 50,000 tCO₂e per year across iron and steel, cement, aluminium, fertilisers and power generation.

A decision by the energy regulator EPDK dated 27 November 2025 set a spot transaction fee of TRY 4.00/tCO₂e for 2026 and an annual participation fee of TRY 100,000. Administrative fines are set out in Communiqué 2026/1 (Official Gazette, 27 December 2025, issue 33120): failure to submit a verified greenhouse gas report carries TRY 627,450 to TRY 6,274,500, with an upper limit of TRY 62,745,000 and an 80% reduction during the pilot period.

Nothing is payable in 2026. The work is making the 2027 invoice predictable, in this order:

1. 1

   Confirm scope at CN code level

   Check each imported line against the current annex rather than assuming sector coverage. The downstream extension is proposed for 2028 and is not yet law.

2. 2

   Test the 50-tonne threshold per importing entity

   The exemption sits with the importer, so it is assessed entity by entity. Separate the entities that cross it — those are where data requests originate.

3. 3

   Get installation-level data from suppliers now

   The default value mark-up reaches +30% in 2028. Every quarter of delay in moving suppliers onto actual data is a premium you pay later.

4. 4

   Document any carbon price paid at origin

   Deductions are only granted where the payment can be evidenced. Set the record-keeping up before the first declaration, not during it.

5. 5

   Model 2027–2030 and put it in the budget

   Factors and price ranges are known, so a forecast is feasible. Show the 2029-to-2030 step change as its own line.

6. 6

   Run EU and UK boundaries in parallel

   If you also import into the UK, the 2027 accounting period starts alongside the EU one with a wider indirect emissions boundary. Build both calculations from the same source data.