What CBAM will cost your imports from 2026 to 2034, and how to estimate it

The EU Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026. Importers of covered goods now buy CBAM certificates against the carbon embedded in what they bring in, and the share they pay for rises every year until 2034. This guide sets out the arithmetic, the schedule and the inputs you need, with the regulation or directive cited for each. It is a cost estimate method, not a customs or registry filing guide.

What changed on 1 January 2026

CBAM is established by Regulation (EU) 2023/956. Annex I lists the covered goods: cement, fertilisers, iron and steel, aluminium, hydrogen and electricity (Regulation (EU) 2023/956, Annex I). During the transitional period importers reported embedded emissions but paid nothing. From 1 January 2026 the definitive period applies: certificates must be bought and surrendered for the chargeable share of embedded emissions.

The bill in 2026 is small because EU free allocation still covers 97.5% of the emissions in the covered sectors. By 2034 free allocation is gone, and the same shipment attracts certificates on 100% of its embedded emissions.

Who has to act: the 50 tonne threshold

Under the 2025 Omnibus simplification, importers above a single mass-based threshold of 50 tonnes of CBAM goods per year must become authorised CBAM declarants and surrender certificates. Below 50 tonnes in a year there is no CBAM obligation. The threshold is by mass of goods, not by emissions or by value, and it is cumulative across all covered goods imported in the year.

How the certificate cost is computed

For each product line the calculation is:

• Embedded emissions per tonne = direct emissions per tonne, plus indirect emissions per tonne where Annex II says they count.
• Total embedded emissions = quantity in tonnes multiplied by embedded emissions per tonne.
• Chargeable emissions = total embedded emissions multiplied by the CBAM factor for the year.
• Net certificate price = the official certificate price, less any carbon price effectively paid in the country of origin, floored at zero.
• CBAM cost = chargeable emissions multiplied by the net certificate price.

Certificates are surrendered in whole units, so the number to buy is the chargeable emissions across all lines rounded up to the next whole tonne of CO2e. Dividing the total cost by the total tonnes of goods gives the cost per tonne of product, which is the number to put beside the purchase price when comparing suppliers.

The CBAM factor and the free allocation phase-out, 2026 to 2034

The CBAM factor is the share of embedded emissions that needs certificates. It is 1 minus the free allocation share for the CBAM sectors set in the EU ETS Directive as amended by Directive (EU) 2023/959, Article 10a(1a).

Source: Directive (EU) 2023/959, Article 10a(1a). The step from 2028 to 2030 is the one to plan for: the chargeable share nearly quintuples in two years.

Direct and indirect emissions: cement and fertilisers versus steel, aluminium and hydrogen

Annex II of the CBAM Regulation lists the goods for which only direct emissions count: iron and steel, aluminium and hydrogen (Regulation (EU) 2023/956, Annex II). For cement and fertilisers, indirect emissions from the electricity consumed in production are included as well. Imported electricity is priced on its own direct generation emissions.

This is the single biggest sector difference. A cement producer running on coal-fired grid electricity carries its power emissions into the CBAM bill; a steel producer on the same grid does not, at least under the current Annex II. If you import cement or fertilisers, you need the indirect figure from the producer or from the Commission's default values; for steel, aluminium and hydrogen you can leave it out.

What a CBAM certificate costs

The Commission publishes the official certificate price. In 2026 it is the quarterly average of EU ETS auction prices; from 2027 it becomes a weekly average. The Q1 2026 price was EUR 75.36 per tonne of CO2e and the Q2 2026 price was EUR 75.28. The current figure is on the Commission's CBAM certificate price page; check it before quoting a number.

No one publishes a forecast of the EU ETS price that you can rely on for 2030. The sensible approach is to run the basket at a range of prices and years and see where the cost becomes material. The Bindler workbook does this on a nine-price by nine-year grid; the free estimator does it for a flat price path and for one you set.

Default values versus verified actual emissions

Embedded emissions per tonne come from one of two places. Where the producer can supply verified actual emissions under the CBAM monitoring rules, use them. Otherwise the Commission publishes default values by CN code and country of origin for the definitive period in an implementing regulation, with a downloadable Excel file on its CBAM legislation and guidance page.

Two things about default values matter for cost. They are revised, so a copy saved last year may be wrong today. And they are set above the country average emission intensity, with a mark-up the Commission is phasing in, so a default-value bill is nearly always higher than an actual-data bill for the same goods. Getting verified data from the producer is usually the cheapest single step an importer can take. Record which values you used and the date you looked them up.

Carbon price paid at origin

Article 9 of the Regulation allows a reduction in the certificates to surrender for a carbon price effectively paid in the country of origin (Regulation (EU) 2023/956, Article 9). Enter only a price that was actually paid and can be documented under the origin scheme. Modelling it as a per-tonne credit against the certificate price, as the Bindler tools do, is a simplification; the formal reduction depends on the origin scheme's design and the documentation the Commission accepts.

A worked example

Assume 1,000 tonnes of steel with direct emissions of 2.0 tCO2e per tonne. That intensity is an assumption for the arithmetic, not a default value; look up the real figure for your CN code and origin. Steel is an Annex II good, so indirect emissions are left out. Total embedded emissions are 2,000 tCO2e.

• 2026: CBAM factor 2.5%, chargeable emissions 50 tCO2e, 50 certificates at EUR 75.36, cost EUR 3,768, or EUR 3.77 per tonne of steel.
• 2030: factor 48.5%, chargeable emissions 970 tCO2e, cost EUR 73,099 at the same price, or EUR 73.10 per tonne.
• 2034: factor 100%, chargeable emissions 2,000 tCO2e, cost EUR 150,720 at the same price, or EUR 150.72 per tonne.

At a flat certificate price the 2034 bill is forty times the 2026 bill. Nothing about the shipment changed; only the free allocation did. If the producer can document a carbon price paid at origin of, say, EUR 20 per tonne, the net price falls to EUR 55.36 and every figure above scales down by the same ratio.

What an estimate does not do

An estimate of this kind does not forecast EU ETS prices, does not replace the CBAM Registry declaration, and does not cover the proposed extension of CBAM to downstream products. It also does not decide whether you are above the 50 tonne threshold in law; it checks the tonnes you enter. Treat it as the number for the budget and the supplier negotiation, and do the filing through the official channels.

The tool that does this

The EU CBAM Cost Calculator 2026-2034 ($29, /cbam-calculator/) is an Excel workbook with a Calculator sheet for up to 20 product lines that applies the Annex II rule by sector, defaults the certificate price to the official Q1 2026 figure, checks the 50 tonne threshold and rounds certificates up; a Projection sheet showing the same basket in every year from 2026 to 2034; a Sensitivity grid across nine certificate prices and nine years; a Default values register for what you looked up and when; and a Sources sheet citing the Regulation, the ETS Directive phase-out schedule and the Commission's price and default-value pages. Live formulas, no macros, no locked cells; works in Excel and Google Sheets.

The free CBAM cost estimator runs one basket for the year you pick and then every year to 2034 in your browser. Nothing leaves your browser.