knowledge 27 April 2026 |

CBAM Certificates: The first quarter pricing unveiled

Key Takeaways

• The first CBAM certificate price has been set at €75.36 for Q1 2026, based on EU ETS allowance prices. Certificates will be available for purchase from February 2027 via a central platform.
• Businesses importing cement, electricity, fertilisers, iron and steel, aluminium, or hydrogen into the EU must register as authorised CBAM declarants and submit annual declarations from 2027.
• CBAM’s scope will expand to 180 downstream products from 1 January 2028, significantly widening the range of affected importers.

First Quarterly Price Announcement

On 7 April 2026, the European Commission (the “Commission”) set the price of CBAM certificates for the first quarter of 2026 at €75.36. This price is calculated according to the average weekly price of EU Emissions Trading System (“EU ETS”) allowances. Prices for the following three quarters will be set on 6 July 2026, 5 October 2026 and 4 January 2027 respectively.

CBAM certificates will be available for purchase on a common central platform (“CCP”) from February 2027. The Commission closed its call for tenders for services to manage the CCP on 6 April 2026, and the platform must be ready for testing by 31 August 2026.

Background

The CBAM was established by a 2023 EU Regulation (the “CBAM Regulation”) and imposes a carbon price on certain goods imported into the EU in an attempt to mitigate “carbon leakage”. Carbon leakage refers to the possibility that (absent the CBAM) businesses would otherwise seek to avoid the economic effects of the EU’s greenhouse gas allowances regime by transferring carbon-intensive production to countries with less stringent climate policies, thereby undermining the EU’s emissions reduction efforts.

Importers of certain goods (set out in Annex I of the CBAM Regulation) will be required to register as an authorised CBAM declarant in order to import goods into the EU customs territory.

CBAM declarants are required to submit a CBAM declaration by 30 September of each year, in respect of the previous year (i.e. for the first time in 2027, in respect of the year 2026). CBAM declarations must contain:

• the total quantity of each type of goods imported in the preceding year;
• the total embedded emissions in those goods, expressed in tonnes of CO₂ equivalent (CO₂e) of emissions; and
• the total number of CBAM certificates to be surrendered (i.e. offset against the declared embedded emissions in imported goods or against the embedded emissions in imported goods that should have been declared) after deducting any carbon price paid abroad and adjusting for free EU ETS allowances.

CBAM certificates are electronic certificates, each representing one tonne of CO₂e embedded in imported goods. From 2027, CBAM declarants are required to surrender certificates corresponding to the embedded emissions contained in their imported goods from 2026 onwards.

Scope of CBAM

For the moment, the CBAM Regulation applies to six broad categories of goods:

• Cement.
• Electricity.
• Fertilisers.
• Iron and steel.
• Aluminium.
• Hydrogen.

The specific goods covered can be found in Annex I of the CBAM Regulation.

In December 2025, the Commission proposed measures to prevent circumvention of the CBAM Regulation, particularly in respect of the steel and aluminium industry. Recognising that carbon leakage may occur through downstream products (such as machinery and appliances containing covered materials), the Commission plans to broaden CBAM’s scope. From 1 January 2028, CBAM will be extended to cover 180 additional downstream products.

Penalties

Failure to surrender the required number of certificates by the relevant deadline will incur a penalty, identical to the excess emissions penalty under the EU ETS, applied for each missing certificate.  Payment of the penalty will not relieve an importer of the obligation to surrender the outstanding certificates. Importers who fail to comply with the CBAM Regulation and introduce goods into the EU without being registered as an authorised CBAM declarant will face penalties three to five times the standard rate of penalty.

Implications for Irish Businesses

Following the United Kingdom’s departure from the European Union, CBAM is likely to have a significant impact on Irish businesses that import goods, given the high volume of trade between Ireland and the UK. Irish businesses importing goods within CBAM’s scope will need to take a number of preparatory steps:

• Review supply chains to identify whether any imported goods fall within the six sectors currently covered by CBAM (cement, electricity, fertilisers, iron and steel, aluminium, and hydrogen) or the 180 downstream products to be covered from 2028.
• Assess embedded emissions data by engaging with third-country suppliers to obtain the emissions data necessary for calculating embedded emissions and determining the number of CBAM certificates required.
• Register as an authorised CBAM declarant, ensuring registration is completed in advance of the first declaration deadline in September 2027. More information on how to register is available on the Commission’s website: CBAM Registry and Reporting.
• Budget for CBAM costs by factoring the cost of CBAM certificates into import planning and pricing, noting that prices will fluctuate quarterly based on EU ETS allowances.
• Consider contractual implications by reviewing contracts with suppliers to allocate responsibility for providing emissions data and address CBAM-related cost pass-through provisions.

How McCann FitzGerald Can Assist

McCann FitzGerald’s Energy team advises Irish and international clients on all aspects of EU energy regulation, including CBAM compliance. If you have any queries in respect of this article or the impact of CBAM generally on your business, please contact one of the Key Contacts listed below.