CBAM puts a carbon price on imports of certain emissions-intensive goods so they face the same cost as EU-produced equivalents under the EU ETS. From the definitive phase in 2026, importers must buy and surrender certificates for their embedded emissions. This planner sizes that obligation and its cost from your own figures.
Which goods are in scope
The definitive CBAM scope covers goods in these sectors, identified by CN code:
| Sector | Examples |
|---|---|
| Iron and steel | Hot-rolled coil, rebar, beams, tubes |
| Aluminium | Unwrought aluminium, profiles, foil |
| Cement | Clinker, Portland cement |
| Fertilisers | Ammonia, urea, nitric acid, ammonium nitrate |
| Electricity | Direct electricity imports |
| Hydrogen | Electrolytic and other hydrogen |
Confirming your exact CN codes against Annex I of Regulation (EU) 2023/956 is the first step — coverage is product-specific and some subheadings are excluded.
How it works
The calculation starts from embedded emissions and nets off carbon already paid abroad before applying the phase-in:
embedded emissions = quantity × emissions factor
foreign credit = (foreign price paid / EU ETS price) × embedded emissions
net certificates = max(0, embedded − foreign credit) × obligation factor
estimated cost = net certificates × EU ETS price
It also estimates the quarterly profile, since importers must hold certificates covering at least 80 percent of cumulative emissions at the end of each quarter, with final surrender once a year.
Worked example
Importing 1,000 tonnes of steel at an embedded factor of 1.9 tCO2e per tonne gives 1,900 tCO2e. With no carbon paid abroad, an EU ETS price of 80 euros, and a full obligation, that is 1,900 certificates costing about 152,000 euros — roughly 380 certificates to hold at each quarterly checkpoint.
Now assume the steel originates from a country with a domestic carbon price of 20 euros per tonne of CO2e already paid:
- Foreign credit: (20 / 80) × 1,900 = 475 certificates offset
- Net certificates: 1,900 − 475 = 1,425
- Estimated cost: 1,425 × €80 = €114,000
The foreign credit reduces the obligation by 25% in this example, illustrating why the origin country’s carbon pricing regime directly affects CBAM cost — and why supplier carbon disclosure is becoming commercially important.
Practical guidance
Use verified installation data (actual embedded emissions from the manufacturer) where available; EU default emissions values apply only when actual data cannot be obtained and tend to be conservative. The phase-in obligation factor will increase as EU ETS free allocations are withdrawn over time, so budget models should plan for rising obligations year on year. Always confirm the current certificate price and your specific CN codes with your CBAM declarant or customs adviser before committing budget.