The European Commission has reached a structuring milestone in the implementation of the Carbon Border Adjustment Mechanism (CBAM) by publishing, on 7 April 2026, the first official certificate price, set at €75.36/tCO₂ for the first quarter of 2026. This signal represents a major step forward in operationalising the mechanism, as it allows operators, for the first time, to rely on a robust economic benchmark to anticipate their carbon exposure. In line with the design of the mechanism, this price is not autonomous but directly indexed to the EU carbon market: it corresponds to the weighted average of auction clearing prices of allowances under the European Union Emissions Trading System (EU ETS), thereby ensuring strict consistency between the carbon cost borne by EU producers and that applied to imports. This approach is fully aligned with the objective of Regulation (EU) 2023/956, which aims to prevent carbon leakage while ensuring a level playing field.
For 2026, the Commission has adopted a transitional mechanism based on the publication of four distinct quarterly prices, each applicable to the emissions embedded in goods imported during the relevant quarter. In other words, the carbon cost will not be determined on the basis of an annual average, but will need to be assessed sequentially, quarter by quarter, depending on the actual timing of importation.
In practical terms, this requires operators to monitor their imports with a high level of granularity, by linking each declaration to the corresponding emissions and to the price applicable for the relevant quarter. The prices for the second, third and fourth quarters will be published respectively in July and October 2026, and in January 2027.
From 2027 onwards, when the obligation to purchase certificates becomes effective, importers will be required to pay an aggregated carbon cost resulting from the sum of emissions declared for each quarter of 2026, valued at the price applicable to each of those quarters. This will therefore not be a single average price, but rather a cost reconstructed on a chronological basis, reflecting the actual pattern of imports carried out.
This development calls for immediate adjustments by operators. First, budgetary anticipation and the integration of carbon costs into pricing structures are becoming tangible, both in commercial relationships with suppliers and in intra-group flows, particularly in light of transfer pricing considerations and cost allocation issues.
Second, ensuring the reliability of emissions data becomes a central challenge, as the final cost will directly depend on reported emissions; in the absence of verified data, the application of default values (often unfavourable) is likely to significantly increase the financial burden.
Several points of attention should nevertheless be highlighted. On the one hand, the inherent volatility of the EU ETS market will be directly reflected in CBAM certificate prices, introducing economic uncertainty that must be factored into sourcing strategies. On the other hand, the interaction with existing carbon pricing mechanisms in third countries remains a sensitive issue, particularly regarding the recognition of carbon prices already paid. Finally, the detailed rules on control and penalties, which will fully apply from 2027, as well as ongoing regulatory developments at EU level, will require close monitoring.