CBAM entered its definitive phase in 2026, adding financial and commercial considerations beyond the obligation to purchase and surrender compliance certificates. Importers, industrial suppliers and financial institutions are required to account for embedded emissions when assessing commodity prices, negotiating supply agreements and calculating working-capital requirements.
CBAM links emissions embedded in imported goods to the EU Emissions Trading System (EU ETS). It introduces carbon pricing into the landed cost of covered commodities, including steel, aluminium, cement, fertilisers, hydrogen and electricity.
EU ETS-linked reference prices for CBAM certificates
The European Commission published CBAM certificate prices for 2026. The certificate price is set at EUR 75.36/tCO₂ for Q1 2026, EUR 75.28/tCO₂ for Q2 2026 and EUR 82.32/tCO₂ for Q3 2026.
In 2026, the certificate price is calculated using the quarterly average of EU ETS auction clearing prices. From 2027, the reference shifts to a weekly average.
This structure exposes importers to movements in the European carbon market even when underlying commodity purchases are concluded under fixed-price agreements. As a result, the carbon component can change independently of the contractual price of imported steel, aluminium or other covered products.
CBAM also differentiates CBAM certificates from EU ETS allowances. CBAM certificates function as compliance instruments rather than freely tradable allowances, and importers cannot rely on a conventional secondary market in CBAM certificates to manage price exposure.
Treasury use of EU ETS instruments alongside certificate obligations
The EU ETS provides market infrastructure for managing carbon-price risk through futures, options and over-the-counter financial structures. These instruments allow companies to lock in or limit exposure to movements in European allowance prices.
CBAM extends EU ETS-linked financial logic to companies that may not operate industrial installations within the European Union. Importers must consider how carbon-price movements affect future certificate requirements and the financial resources needed to meet obligations.
The distinction between compliance instruments and available hedging instruments is relevant for treasury departments. Using EU ETS-linked financial products does not replace the obligation to calculate, acquire and surrender the required CBAM certificates.
Procurement comparisons based on embedded emissions and documentation
CBAM changes how European buyers compare suppliers during procurement. Decisions must consider more than quoted commodity prices, freight, tariffs and payment conditions.
The emissions profile of each imported product can influence final landed cost under CBAM. Buyers also need to assess whether a carbon price paid in the country of origin can be recognised under applicable CBAM rules and how many certificates will ultimately be surrendered.
A supplier with a lower headline price may become less competitive once embedded emissions and associated carbon costs are included in purchasing calculations. This affects negotiations between European importers and producers in third countries.
Verified emissions information and supporting documentation become commercial factors alongside product specifications, delivery schedules and payment terms. Procurement therefore requires additional inputs when structuring cross-border supply arrangements.
Coordination across corporate functions for CBAM-related liquidity
The financial implications of CBAM are distributed across corporate functions with separate responsibilities. Procurement manages physical supply agreements and supplier negotiations.
Sustainability teams are responsible for emissions information, while customs departments oversee import declarations. Treasury manages exposure to EU ETS-linked carbon prices and foreign exchange movements.
Finance provides liquidity required for certificate purchases and related financial obligations. Without coordination among these functions, companies risk leaving material carbon-price exposure outside established purchasing and financial risk-management procedures.
Carbon-adjusted landed cost framework for supplier evaluation
An approach described for assessing imports uses a consistent carbon-adjusted landed-cost framework. Companies connect the physical quantity of imported goods with embedded emissions, applicable free-allocation adjustments and any eligible deduction for carbon prices paid in the country of origin.
The calculation also incorporates expected CBAM certificate price, foreign exchange exposure, financing costs and verification risks. For industrial buyers, this framework supports comparing suppliers and evaluating contractual offers using conventional commodity costs alongside financial consequences tied to embedded emissions.
For treasury and finance departments, it brings CBAM exposure into working-capital planning and carbon-price risk management. The definitive CBAM regime extends carbon-market pricing influence into industrial trade, supplier relationships and corporate financial management.