� CBAM �
Figure 1: Calculation of annual CBAM certificate demand and relevant data sources( without considering CO2 prices paid in the upstream supply chain)( source: carboneer)
a mark-up for data gaps, and CBAM benchmarks.
Importers must purchase and hold CBAM certificates by the end of each quarter representing 50 % of imported emissions during the import year. The year 2026 will be an exception as CBAM certificates can only be purchased from February 2027 onwards. The price of CBAM certificates is calculated from the average weekly price of allowances in EU ETS. Prices for emission allowances in the EU ETS fluctuated between 50 and 100 EUR / tCO2 in 2023-2024. Due to tightening EU climate policies, they are projected to rise further, reaching 120 to 200 EUR / tCO2 by 2030. Combined, these factors pose a challenge for accurately estimating CBAM certificate costs.
From the perspective of an importer, it is advantageous to know future CBAM costs today and when payments are due. Otherwise, the strategic relevance of the issue and the impact on risk and liquidity management of this additional financial burden may be misjudged. A solid forecast of expected costs enables:
• Planning the budget for purchasing CBAM certificates,
• Developing a purchasing strategy for acquiring CBAM certificates to avoid buying at peak prices,
• Understand price uncertainties of CBAM certificates and thus costs for imported goods,
• Adjusting supplier and customer contracts to avoid bearing CBAM costs alone,
• Integrating the impact of CBAM into strategic purchasing decisions.
To illustrate the cost management approach, the
following case study uses an annual import volume of 100,000 tons of steel ingots.
Demand for CBAM certificates
Calculating the number of CBAM certificates to be surrendered for importing goods within a calendar year is the starting point for further analysis. For simplicity, we assume that no CO2 prices were paid in the upstream supply chain. Figure 1 shows the key parameters of the calculation formula.
CBAM benchmarks are expected to be published in Q4 2025 and will be based on the benchmarks for determining free allocations in EU ETS. While CBAM benchmarks will be officially announced relatively shortly before 2026, a good estimate of CBAM certificate demand
Green Steel World | Issue 18 | June 2025 13