Companies importing goods covered by the Carbon Border Adjustment Mechanism (CBAM) in 2026 will be subject to four quarterly certificate prices rather than a single annual carbon price. The European Commission will assign a separate price to each quarter of import, creating four distinct carbon-cost vintages during the first year of the definitive regime. The approach affects margin analysis, supplier comparisons, financial provisioning and year-end reporting.
The published certificate prices are €75.36 per tonne of CO₂ for the first quarter, €75.28 for the second and €82.32 for the third quarter. The fourth-quarter price is scheduled for publication on 4 January 2027. Certificate requirements for 2026 imports are calculated from embedded emissions recorded for goods imported during each quarter.
For those 2026 imports, the corresponding quarterly certificate price is applied when certificates become available for purchase in 2027. This links the timing of import to the cost of certificates used later in the compliance process. Importers therefore need to track quarter-specific emissions inputs alongside the relevant price period.
Quarterly certificate pricing links import timing to carbon costs
The quarterly pricing structure means that even with stable physical volumes, carbon costs can change when deliveries fall into different pricing periods. Goods arriving in a higher-price quarter can result in a greater certificate cost while product specifications and emissions intensity remain unchanged.
A shift to a supplier with lower verified embedded emissions may offset part of an increase driven by EU carbon market movements. Procurement and finance teams are expected to keep the import date and corresponding emissions information together rather than averaging exposure across the year too early.
Exposure from 2026 imports continues to accumulate even though the first annual CBAM declaration and certificate-surrender deadline is 30 September 2027. Management reporting is expected to connect physical imports, estimated certificate requirements and anticipated cash outflows, rather than relying only on a year-end sustainability report.
Provisional emissions assumptions before verification and surrender
CBAM introduces different timelines for imports, emissions verification and certificate pricing. Goods may enter the EU before verified actual emissions data are available, while the applicable certificate price follows the quarterly schedule.
Companies therefore need a provisional emissions assumption and a method for updating estimates once verified data are received. Recognising exposure only after final verification could lead businesses to identify substantial historical costs after customer prices have already been agreed.
A disciplined accrual process is described as enabling finance teams to recognise expected liabilities while clearly identifying assumptions that remain provisional. A control file should support a quarter-by-quarter reconciliation from customs entries to covered quantities, specific embedded emissions, any applicable free-allocation adjustment, any eligible deduction for carbon prices paid abroad and the relevant certificate price.
Contract terms may require true-ups as prices and verification change
The quarterly mechanism also affects commercial agreements under which CBAM costs are passed through. A fixed CBAM surcharge agreed at the beginning of the year can produce unexpected gains or losses if EU ETS prices change or if verified emissions differ from initial estimates.
More robust contracts can include a calculation formula linked to official certificate prices and agreed emissions data, followed by an adjustment once verification is complete. The agreement should distinguish provisional information from verified values and define which changes trigger a price true-up.
An example scenario involves a supplier providing an estimated emissions intensity first and later submitting an accredited verification report. At the same time, the official certificate price may change between contract negotiation and settlement, making defined adjustment mechanisms relevant for dispute reduction and cost estimation without waiting for every input to be final.
Quarter-specific records for Western Balkan exporters preparing EU offers
Exporters in Serbia and the wider Western Balkans can apply similar approaches when preparing offers for EU customers. Instead of quoting a generic CBAM premium, they can show how verified emissions intensity affects estimated certificate quantity while treating the official EU certificate price as an external market variable.
This distinction is intended to help buyers identify which elements of potential cost depend on supplier performance versus those driven by carbon market conditions. It can also support more consistent supplier comparisons when products arrive in different quarters or use different emissions assumptions.
Finance teams are expected to maintain separate quarterly cost records for 2026 rather than relying on a single annual proxy before final calculation requirements are met. Contracts for late-year deliveries should specify how the relevant import quarter is determined and how subsequent emissions corrections or other adjustments are handled.
Linking customs, procurement and finance documentation for auditability
A practical implementation test is whether a company can explain its calculation to both an auditor and a commercial manager using the same underlying records. CBAM documentation should connect purchasing, production, customs and finance rather than operate as a standalone compliance file.
Routine operational data, controlled assumptions and documented fallback methods allow companies to reflect changes in suppliers, transport routes, prices or legal requirements without rebuilding calculations. The minimum decision file should link customs volumes, the emissions basis, certificate prices, expected cash timing and contractual cost pass-through, including identification of who approves each assumption.
A fallback should also be documented where preferred emissions treatment cannot be substantiated. Although an alternative may be commercially less favourable, defining it early reduces the risk of discovering actual exposure only when a verifier, customs authority or authorised declarant challenges a claim.
Consistent records are described as making later price adjustments, verification changes and management reporting easier to defend as CBAM’s financial effects grow. With four quarterly certificate prices in place, import quarter selection becomes an important variable in carbon-cost and invoice economics.