[{"data":1,"prerenderedAt":299},["ShallowReactive",2],{"blog:\u002Fblog\u002Fcbam-certificate-price-quarterly-2026":3},{"id":4,"title":5,"body":6,"date":284,"description":285,"extension":286,"hero":287,"heroAlt":287,"keywords":288,"meta":289,"navigation":290,"path":291,"readingMinutes":292,"seo":293,"stem":294,"tags":295,"__hash__":298},"blog\u002Fblog\u002Fcbam-certificate-price-quarterly-2026.md","The CBAM price for this quarter doesn't exist yet",{"type":7,"value":8,"toc":273},"minimark",[9,13,16,21,29,32,72,75,81,85,88,95,98,132,135,139,142,148,151,159,163,166,187,190,202,205,209,216,223,226,230,240,246,252,258,262,265,268],[10,11,12],"p",{},"Today is the fifth of September. If you imported CBAM goods in July, you still cannot say what those\nimports cost you.",[10,14,15],{},"Not because your data is incomplete. Because the number does not exist yet.",[17,18,20],"h2",{"id":19},"how-the-price-is-set-in-2026","How the price is set in 2026",[10,22,23,24,28],{},"A CBAM certificate is priced off the EU Emissions Trading System, but not off the live market. In\n2026 the price is the ",[25,26,27],"strong",{},"quarterly average of EU-ETS auction prices",", published by the Commission\n(Art. 21(1a) of Regulation (EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083; the cadence is set\nout in Implementing Regulation (EU) 2025\u002F2548, Art. 1(6)).",[10,30,31],{},"Two published figures exist so far:",[33,34,35,48],"table",{},[36,37,38],"thead",{},[39,40,41,45],"tr",{},[42,43,44],"th",{},"Period",[42,46,47],{},"Price per tonne CO₂",[49,50,51,62],"tbody",{},[39,52,53,57],{},[54,55,56],"td",{},"Q1 2026",[54,58,59],{},[25,60,61],{},"€75.36",[39,63,64,67],{},[54,65,66],{},"Q2 2026",[54,68,69],{},[25,70,71],{},"€75.28",[10,73,74],{},"Q3 is not among them. An average of a quarter can only be computed once the quarter is over, so the\nQ3 figure is expected in early October — after every Q3 import has already cleared customs.",[10,76,77,78],{},"That is not a gap in the rules. It is what \"quarterly average\" means. But it has a consequence people\nrarely plan for: ",[25,79,80],{},"for roughly three months of every quarter, the price attached to your imports is\nunknowable.",[17,82,84],{"id":83},"the-number-attaches-to-the-import-not-to-the-purchase","The number attaches to the import, not to the purchase",[10,86,87],{},"This is the part that gets misfiled.",[10,89,90,91,94],{},"The price is resolved by the ",[25,92,93],{},"period of importation"," — not by the date you buy the certificate, not\nby the date you file. An import in July is valued at the Q3 price whether you compute it in July, in\nOctober, or in September 2027 when the annual declaration is due.",[10,96,97],{},"So the sequence for a July import is:",[99,100,101,108,114,120,126],"ol",{},[102,103,104,107],"li",{},[25,105,106],{},"July:"," the goods arrive. The obligation is fixed in tonnes of CO₂.",[102,109,110,113],{},[25,111,112],{},"July–September:"," the price for that obligation does not exist.",[102,115,116,119],{},[25,117,118],{},"Early October:"," the Commission publishes the Q3 average. Only now is the euro figure knowable.",[102,121,122,125],{},[25,123,124],{},"From 1 February 2027:"," certificates can actually be bought.",[102,127,128,131],{},[25,129,130],{},"30 September 2027:"," the annual declaration is due.",[10,133,134],{},"Between steps 1 and 3 you have a liability with a known quantity and an unknown price. That is a\nperfectly ordinary accounting situation — but only if you treat it as one.",[17,136,138],{"id":137},"the-eight-cents-that-change-the-argument","The eight cents that change the argument",[10,140,141],{},"Here is where the intuition usually goes wrong. \"Quarterly price\" sounds like exposure to swings, so\nthe instinct is to worry about how far the number can move between quarters.",[10,143,144,145],{},"Look at what actually happened. ",[25,146,147],{},"€75.36 to €75.28 — a difference of eight cents, about 0.1 %.",[10,149,150],{},"On 500 tonnes of CO₂, the two published quarters differ by forty euros. Whatever the risk in this\nmechanism is, it is not that the quarterly figure lurches.",[10,152,153,154,158],{},"Two caveats before anyone plans around that. Two quarters is not a trend, and the ETS itself is\nperfectly capable of moving; the quarterly average smooths daily movement, it does not remove it.\nWhat the smoothing does mean is that a quarterly average is a ",[155,156,157],"em",{},"slow"," number by construction. The risk\nin a slow number is not that it jumps. It is that you book something else in its place and forget.",[17,160,162],{"id":161},"what-people-book-instead","What people book instead",[10,164,165],{},"When the real figure is missing, something has to go in the cell. In practice it is one of three\nthings:",[167,168,169,175,181],"ul",{},[102,170,171,174],{},[25,172,173],{},"The live ETS price",", taken from a market feed on the day of the calculation.",[102,176,177,180],{},[25,178,179],{},"The last published quarter",", carried forward.",[102,182,183,186],{},[25,184,185],{},"A round number",", agreed once and never revisited.",[10,188,189],{},"All three are defensible as an accrual. None of them is the CBAM price, and that distinction survives\ninto the audit.",[10,191,192,193,196,197,201],{},"The failure is not choosing a proxy — you have to. The failure is a figure that no longer remembers\nit ",[155,194,195],{},"was"," a proxy. Six months later the cell says ",[198,199,200],"code",{},"75.28"," and nobody can tell whether that is the\npublished Q2 average, a carried-forward guess, or a market quote from a Tuesday.",[10,203,204],{},"Any system that values CBAM obligations should carry the provenance next to the number: which period,\nwhich source, published or estimated. Ours refuses to substitute silently — when the quarterly figure\nis missing it falls back, but the result says so, and a figure marked as an estimate can never be\nmistaken for a published one. That is not a clever feature. It is the minimum for a number that will\nbe re-stated later.",[17,206,208],{"id":207},"_2027-changes-the-shape-of-this-problem","2027 changes the shape of this problem",[10,210,211,212,215],{},"From 2027 the cadence moves from quarterly to ",[25,213,214],{},"weekly"," (same provisions). That mostly solves the\nwaiting: a week's average is available days after the week ends, not months.",[10,217,218,219,222],{},"It replaces it with a bookkeeping problem. Fifty-two prices a year instead of four means the ",[25,220,221],{},"date\nof each import"," stops being a detail and becomes the key that selects the price. If your import\nrecords are precise to the month, they are precise enough for 2026 and not for 2027.",[10,224,225],{},"That is worth checking now, while the consequence of getting it wrong is still small. Being in the\nwrong quarter is a rounding error today. Being in the wrong week, once the price moves weekly, is a\nnumber you cannot reconstruct without going back to the customs data.",[17,227,229],{"id":228},"what-to-do-this-week","What to do this week",[10,231,232,235,236,239],{},[25,233,234],{},"1. Find out what price your current figures are using."," Not the value — the ",[155,237,238],{},"source",". If the\nanswer is \"the ETS price\" or \"whatever was in the sheet\", that is fine as an accrual and a problem as\na record. Write down which it is, next to the number.",[10,241,242,245],{},[25,243,244],{},"2. Check that every import carries its own import date."," Not the invoice date, not the month.\nThe import date is what selects the price, and from 2027 it selects it to the week.",[10,247,248,251],{},[25,249,250],{},"3. Put a note in the calendar for early October."," When the Q3 figure publishes, your Q3 accruals\nbecome re-statable. If nobody owns that step, the proxy quietly becomes the final number.",[10,253,254,257],{},[25,255,256],{},"4. Do not price certificates you cannot yet buy."," Trading opens on 1 February 2027. Anything\nbefore that is provisioning, not purchasing — and provisioning against a price that has not been\npublished is provisioning against an estimate, however precise the spreadsheet looks.",[17,259,261],{"id":260},"the-part-that-is-genuinely-unresolved","The part that is genuinely unresolved",[10,263,264],{},"The Commission publishes the quarterly figure; it does not publish it on a statutory date that we\nhave been able to point to. \"Early October\" is an expectation drawn from the mechanics of a quarterly\naverage, not a deadline we can cite. If your process depends on the figure landing by a particular\nday, that dependency is on an assumption — plan for it to be late rather than discover that it is.",[266,267],"hr",{},[10,269,270],{},[155,271,272],{},"This article explains the rules as we read them; it is not legal advice. The pricing mechanism is\nset out in Regulation (EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083, and in Implementing\nRegulation (EU) 2025\u002F2548. Published quarterly figures come from the Commission. Check your own\nposition with your customs agent or the competent authority in your member state — in Germany, the\nDEHSt.",{"title":274,"searchDepth":275,"depth":275,"links":276},"",2,[277,278,279,280,281,282,283],{"id":19,"depth":275,"text":20},{"id":83,"depth":275,"text":84},{"id":137,"depth":275,"text":138},{"id":161,"depth":275,"text":162},{"id":207,"depth":275,"text":208},{"id":228,"depth":275,"text":229},{"id":260,"depth":275,"text":261},"2026-09-05","In 2026 the certificate price is a quarterly average the Commission publishes after the quarter has ended. So for three months you are importing against a number nobody can look up — and the two published quarters differ by eight cents, which tells you the real risk is timing, not volatility.","md",null,"CBAM certificate price, CBAM Zertifikatspreis, CBAM quarterly average, CBAM weekly price 2027, Art 21(1a) CBAM, Regulation 2025\u002F2083, CBAM accrual, CBAM certificate price Q3 2026",{},true,"\u002Fblog\u002Fcbam-certificate-price-quarterly-2026",6,{"title":5,"description":285},"blog\u002Fcbam-certificate-price-quarterly-2026",[296,297],"compliance","pricing","i9EJE9Gm9a-tILwELUAuw5fY4btJ2UuhkSa_JRrmprc",1790002810922]