CBAM in 2027: importers need a precise plan for certificate purchases

From 1 February 2027, EU member states will begin selling certificates under the carbon border adjustment mechanism, with purchases processed through a central platform integrated with the CBAM registry. A single application can cover between 1 and 99,999 certificates. Under the draft rules, once a purchase application has been submitted its content cannot be changed, and withdrawal will only be possible before payment is completed. Settlements will be processed in euro, and each certificate purchased will carry an administrative fee of EUR 0.05.

The certificate price itself is not negotiable – it is derived from the weighted average of EU ETS allowance auction prices. The European Commission set it at EUR 75.36 per tonne of CO₂ in the first quarter of 2026 and EUR 75.28 in the second. From 2027 onwards, publication will move from a quarterly to a weekly cycle, narrowing the gap between allowance quotations and the certificate purchase price.

The European Commission estimates that once the 50-tonne threshold is introduced, around 18,000 importers will remain within the mechanism's scope, down from the previous 200,000. Poland is overrepresented in this group: 3,256 domestic declarants were registered during the transitional period – the second-highest figure in the entire European Union. The Commission has concluded consultations on the draft regulation setting out the mechanics of certificate purchase and repurchase. The most important changes concern the centralization of transactions and the rules for settling surpluses.

Only one repurchase application per year

Importers will be able to submit one repurchase application per year. To use this option, the required number of certificates must first be surrendered by 30 September of the given year, and the application itself needs to be submitted by 31 October – failure to meet this deadline will result in the loss of the right to repurchase. The scope of repurchase is further limited: it covers only the number of certificates the declarant was required to acquire that year under the quarterly obligation. The authority reviews applications three times a year – 1 April, 1 July and 1 November – and has 42 days to do so.
A certificate left unused on the account cannot be bought back from the importer by any other company. Certificates which are neither surrendered nor covered by repurchase are cancelled without compensation on 1 November. Therefore, excess purchases become an unrecoverable cost. This means that forecasts of import, goods volumes and embedded emissions will directly shape financial planning.

2027: two compliance tracks in parallel

From 2027, purchasing certificates will require importers to plan on an ongoing basis, rather than simply settling obligations once the reporting period ends. It will be the initial year in which the mechanism will follow two tracks at the same time. The first is the settlement of 2026 with declaration and surrender of certificates by 30 September 2027. The second is a new quarterly obligation: starting 31 March 2027, at the end of each quarter the authorised declarant's account is required to hold a number of certificates equivalent to at least 50 percent of the embedded emissions in goods imported since the beginning of the year. Companies should therefore be prepared to combine customs data, information obtained from suppliers, and import volume forecasts with the CBAM timetable.

Costs will rise, and the mechanism's scope will expand

Companies should plan beyond one year, as the financial burden will gradually increase. The mechanism is being phased out in parallel with free ETS allowances: in 2026, importers will pay for 2.5 percent of embedded emissions; in 2027 – 5 percent; in 2030 – 48.5 percent, reaching the full 100 percent by 2034. The markup on default values – applied when an importer has not received verified data from a supplier – is rising, as well, from 10 percent in 2026 to 20 percent in 2027 and, effective from 2028, to 30 percent for steel, aluminium, cement and hydrogen. The default values themselves are no longer fixed either: implementing regulation 2026/1740, published on 31 July 2026, corrects them retroactively from 1 January 2026, so companies which calculated emissions using previously downloaded tables are obliged to recalculate them.

At the same time, the mechanism's scope itself is expanding. The European Commission has proposed bringing 180 processed products with a high steel and aluminium content – i.a. metal structures, machinery and automotive components – under CBAM from 1 January 2028. The Council of the EU adopted a general approach on 12 June 2026 and supported the including of post-production scrap into the mechanism, while the European Parliament's Environment Committee came out in favour of extending it to more than 400 product codes. The final list is still under negotiation, which is why it is worth starting a review of tariff classification, origin and the supplier base now.

How to prepare for the new rules?

Despite the narrowing of the mechanism's scope, Poland remains one of the key markets where preparing for the new obligations will be particularly important. Companies should organise their customs data, information regarding the origin and weight of goods, as well as their embedded emissions data, and import forecasts.

At Rohlig SUUS Logistics, we support businesses at every stage of CBAM obligations compliance – from reporting and calculating emissions, through obtaining authorised declarant status and preparing annual declarations, to planning settlements and certificate purchases.
The draft regulation on the sale and repurchase of certificates has not yet been adopted, so its final wording may change. The sales start date – 1 February 2027 – follows from the regulations currently in force.