The CBAM price for this quarter doesn't exist yet

Today is the fifth of September. If you imported CBAM goods in July, you still cannot say what those imports cost you.

Not because your data is incomplete. Because the number does not exist yet.

How the price is set in 2026

A CBAM certificate is priced off the EU Emissions Trading System, but not off the live market. In 2026 the price is the quarterly average of EU-ETS auction prices, published by the Commission (Art. 21(1a) of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083; the cadence is set out in Implementing Regulation (EU) 2025/2548, Art. 1(6)).

Two published figures exist so far:

Q3 is not among them. An average of a quarter can only be computed once the quarter is over, so the Q3 figure is expected in early October — after every Q3 import has already cleared customs.

That is not a gap in the rules. It is what "quarterly average" means. But it has a consequence people rarely plan for: for roughly three months of every quarter, the price attached to your imports is unknowable.

The number attaches to the import, not to the purchase

This is the part that gets misfiled.

The price is resolved by the period of importation — not by the date you buy the certificate, not by the date you file. An import in July is valued at the Q3 price whether you compute it in July, in October, or in September 2027 when the annual declaration is due.

So the sequence for a July import is:

1. July: the goods arrive. The obligation is fixed in tonnes of CO₂.
2. July–September: the price for that obligation does not exist.
3. Early October: the Commission publishes the Q3 average. Only now is the euro figure knowable.
4. From 1 February 2027: certificates can actually be bought.
5. 30 September 2027: the annual declaration is due.

Between steps 1 and 3 you have a liability with a known quantity and an unknown price. That is a perfectly ordinary accounting situation — but only if you treat it as one.

The eight cents that change the argument

Here is where the intuition usually goes wrong. "Quarterly price" sounds like exposure to swings, so the instinct is to worry about how far the number can move between quarters.

Look at what actually happened. €75.36 to €75.28 — a difference of eight cents, about 0.1 %.

On 500 tonnes of CO₂, the two published quarters differ by forty euros. Whatever the risk in this mechanism is, it is not that the quarterly figure lurches.

Two caveats before anyone plans around that. Two quarters is not a trend, and the ETS itself is perfectly capable of moving; the quarterly average smooths daily movement, it does not remove it. What the smoothing does mean is that a quarterly average is a slow number by construction. The risk in a slow number is not that it jumps. It is that you book something else in its place and forget.

What people book instead

When the real figure is missing, something has to go in the cell. In practice it is one of three things:

• The live ETS price, taken from a market feed on the day of the calculation.
• The last published quarter, carried forward.
• A round number, agreed once and never revisited.

All three are defensible as an accrual. None of them is the CBAM price, and that distinction survives into the audit.

The failure is not choosing a proxy — you have to. The failure is a figure that no longer remembers it was a proxy. Six months later the cell says 75.28 and nobody can tell whether that is the published Q2 average, a carried-forward guess, or a market quote from a Tuesday.

Any system that values CBAM obligations should carry the provenance next to the number: which period, which source, published or estimated. Ours refuses to substitute silently — when the quarterly figure is missing it falls back, but the result says so, and a figure marked as an estimate can never be mistaken for a published one. That is not a clever feature. It is the minimum for a number that will be re-stated later.

2027 changes the shape of this problem

From 2027 the cadence moves from quarterly to weekly (same provisions). That mostly solves the waiting: a week's average is available days after the week ends, not months.

It replaces it with a bookkeeping problem. Fifty-two prices a year instead of four means the date of each import stops being a detail and becomes the key that selects the price. If your import records are precise to the month, they are precise enough for 2026 and not for 2027.

That is worth checking now, while the consequence of getting it wrong is still small. Being in the wrong quarter is a rounding error today. Being in the wrong week, once the price moves weekly, is a number you cannot reconstruct without going back to the customs data.

What to do this week

1. Find out what price your current figures are using. Not the value — the source. If the answer is "the ETS price" or "whatever was in the sheet", that is fine as an accrual and a problem as a record. Write down which it is, next to the number.

2. Check that every import carries its own import date. Not the invoice date, not the month. The import date is what selects the price, and from 2027 it selects it to the week.

3. Put a note in the calendar for early October. When the Q3 figure publishes, your Q3 accruals become re-statable. If nobody owns that step, the proxy quietly becomes the final number.

4. Do not price certificates you cannot yet buy. Trading opens on 1 February 2027. Anything before that is provisioning, not purchasing — and provisioning against a price that has not been published is provisioning against an estimate, however precise the spreadsheet looks.

The part that is genuinely unresolved

The Commission publishes the quarterly figure; it does not publish it on a statutory date that we have been able to point to. "Early October" is an expectation drawn from the mechanics of a quarterly average, not a deadline we can cite. If your process depends on the figure landing by a particular day, that dependency is on an assumption — plan for it to be late rather than discover that it is.

This article explains the rules as we read them; it is not legal advice. The pricing mechanism is set out in Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083, and in Implementing Regulation (EU) 2025/2548. Published quarterly figures come from the Commission. Check your own position with your customs agent or the competent authority in your member state — in Germany, the DEHSt.