Put CBAM on your proforma: surcharge per line and a revision clause

For each line, the certificates your buyer surrenders per tonne are the embedded emissions it declares less the free allocation adjustment. Without a verified figure from you, the buyer must declare the EU default value for the country of production plus a mark-up of 10% for 2026 imports, 20% for 2027 and 30% from 2028 (1% for fertilisers). The free allocation adjustment is the EU benchmark times the CBAM factor of the import year, which falls from 97.5% in 2026 to 0 in 2034. The surcharge per tonne is those certificates times the certificate price: the same figures as the cost calculator.

A verified figure replaces the default and its mark-up, so it usually lowers the surcharge. With one, the free allocation deducted is the benchmark for the default route, an approximation; your buyer's declarant works out the exact figure.

If a carbon price was paid for the goods in the country of production, the buyer can reduce its certificates by it (Article 9 of Regulation (EU) 2023/956); the rules for that deduction are not final, so the sheet shows the surcharge before it and the clause says so.

For goods imported in a given year the certificates per tonne are set by the default value or your verified figure; what moves is the price. For 2026 imports the Commission publishes one price per quarter, and it is the price of the certificates for goods imported in that quarter. From 2027 it publishes a price every week, and your buyer pays the price of the week in which it buys certificates, which can be months after import. So the clause uses an agreed reference: the average of the weekly prices of the quarter of import. Stating the certificates per tonne (C) and the price used (P) lets the final invoice apply P for the actual import, with the difference charged or credited. C is stated for one import year: goods imported in another year, or a change to the default values or benchmarks, change it.

Who bears CBAM is a commercial choice: the importer is the one who declares and surrenders certificates. The CBAM contract clause sets the wider rules (data, deadlines, late data), and the own-emissions calculator shows whether a verified figure would lower the surcharge.