� CBAM �
Figure 3: CBAM certificate procurement strategies based on exemplary CBAM certificate prices in 2023( left) and mid-term financial hedge for CBAM certificates required in 2026-2028 via the EU ETS( right)( source: carboneer CBAMCC model)
to 10 % of cost savings. A further risk management approach is to hedge costs by purchasing emission allowances in the EU ETS. These allowances can be resold at the time of CBAM certificate purchase, enabling medium- to long-term hedging of CBAM costs( compare examples in figure 3).
For effective risk and cost management a strategic approach should consider company-specific characteristics concerning: for the imported emissions corresponding to the allowance price in the EU ETS. CBAM is not just a regulatory issue – it changes global trade. However, companies can prepare for the changes through wellfounded cost analyses, strategic procurement, and intelligent price hedging.
CBAM remains subject to significant regulatory uncertainty and dynamics: several changes have been proposed by the EU Commission in late February
2025 and up to 10 legal acts are expected to be adopted in 2025. Therefore, some of the deadlines or rules mentioned above may still change. A decision to extend CBAM to additional sectors and further downstream products of affected sectors is also pending in the coming months. The determination of emission data in traded products, their efficient communication in the supply chain and understanding cost implications will play an increasingly important role in the coming years.
• Liquidity constraints and risk profile,
• Potential for cost passthrough in the supply chain,
• Planning and purchasing / import processes and periods,
• Price volatility in EU ETS.
Summary and outlook
CBAM obliges importers of certain products to report emission data from the supply chain and, for imports from 2026, to pay a CO2 price
About the authors
Simon Göß is an energy engineer and expert on energy and carbon markets and managing director at carboneer. He led consultancy projects, studies and more than 200 workshops and trainings on energy and carbon markets, trading and policy.
Hendrik Schuldt is an environmental economist, climate policy advisor and managing director at carboneer. He previously worked at the Potsdam Institute for Climate Impact Research( PIK).
Green Steel World | Issue 18 | June 2025 15