Plan your CBAM certificates: quarterly holding and surrender

From 2027, at the end of each quarter you must have CBAM certificates on your registry account for at least 50% of the embedded emissions of everything you imported since 1 January. The emissions are worked out from the EU default values without the mark-up, less the free allocation adjustment (Article 22(2)). You may instead base it on the certificates you surrendered for the year before, if you import the same CN codes from the same countries; this planner uses the default-value basis.

The first check falls at the end of the quarter after the one in which your CBAM imports pass 50 tonnes for the year (Article 22(2a)). At or under 50 tonnes in a year, no CBAM obligation applies to those goods (Article 2a). The threshold counts all your CBAM goods together, so enter every supplier; hydrogen is outside it and always due. The planner works one import year at a time.

By 30 September you declare the previous year's imports and surrender their certificates (for 2026 imports: by 30 September 2027). Without verified figures from your supplier, each tonne counts at the EU default value plus a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). A supplier's verified figure usually costs you fewer certificates: ask your supplier for it.

Certificates go on sale on 1 February 2027. For 2026 imports the price is the average of the quarter in which the goods were imported; from 2027 it is set every week. Certificates you hold beyond the surrender can be sold back if you ask by 31 October of the surrender year, up to the number the quarterly holding made you buy (Article 23); those bought in 2027 for 2026 imports only in 2027. Certificates left on the account are cancelled on 1 November (Article 24).