How to Budget for CBAM Costs in 2026: Financial Guide for Importers

Here's the mistake most SME importers make: they look at their 2026 CBAM bill, see a small number, and assume that's what they'll pay next year.

It's not. Your 2034 bill will be roughly 40 times higher — for the same imports.

CBAM costs grow as free allocation phases out. If you're budgeting using only 2026 numbers, you're building a financial plan that breaks in 2029.

This guide walks through the actual numbers — sector by sector — so you can build a realistic 5-year budget.

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The CBAM Cost Formula

Four inputs. That's it.

Step 1: Calculate embedded emissions

Embedded emissions (tCO₂e) = Quantity (tonnes) × Emission factor (tCO₂e/tonne)

Step 2: Apply the CBAM factor

Chargeable emissions = Embedded emissions × (1 − CBAM factor)

Source: Regulation (EU) 2023/956, Annex VIII

Step 3: Calculate certificate cost

Certificate cost (EUR) = Chargeable emissions × Certificate price (EUR/tCO₂e)

Step 4: Deduct any carbon price paid at origin

Net CBAM cost = Certificate cost − Carbon price deduction

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The Phase-Out Schedule That Changes Everything

Most of the financial impact isn't in 2026. It's in 2029–2030, when the free allocation offset drops sharply.

Year	CBAM factor (free allocation offset)	Net liable share	Cost vs. 2026
2026	97.5%	2.5%	1×
2027	95%	5%	2×
2028	90%	10%	4×
2029	77.5%	22.5%	9×
2030	51.5%	48.5%	19×
2031	39%	61%	24×
2032	26.5%	73.5%	29×
2033	14%	86%	34×
2034	0%	100%	40×

Source: Regulation (EU) 2023/956, Annex VIII — CBAM factor phase-out schedule

The jump between 2028 and 2029 is the biggest single increase — net liable share goes from 10% to 22.5% in one year. That's a 125% increase.

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2026 Certificate Price: The Starting Point

The first official CBAM certificate price was published on April 7, 2026:

Period	Price	Method
Q1 2026	€75.36/tCO₂	Quarterly average of EU ETS auctions
Q2 2026	~€80 (est.)	Published July 6, 2026
Q3 2026	TBD	Published October 5, 2026
Q4 2026	TBD	Published January 4, 2027

Source: European Commission, DG TAXUD — Price of CBAM certificates page

Starting 2027, prices switch to weekly averages. That means more fluctuation. Plan for it.

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Steel Importer Budget: Two Scenarios

Scenario A: BF-BOF (blast furnace) — 1,000 tonnes/year

Year	Liable emissions	Est. price	Annual cost
2026	47.5 tCO₂	€75	~€3,600
2027	95 tCO₂	€80	~€7,600
2028	190 tCO₂	€85	~€16,200
2029	427.5 tCO₂	€90	~€38,500
2030	921.5 tCO₂	€95	~€87,500
2034	1,900 tCO₂	€100	~€190,000

Scenario B: EAF (electric arc) — 1,000 tonnes/year

Year	Liable emissions	Est. price	Annual cost
2026	15 tCO₂	€75	~€1,100
2027	30 tCO₂	€80	~€2,400
2028	60 tCO₂	€85	~€5,100
2029	135 tCO₂	€90	~€12,200
2030	291 tCO₂	€95	~€27,600
2034	600 tCO₂	€100	~€60,000

EAF producers pay about a third of what BF-BOF producers pay — at every stage.

Note: Steel benchmarks from IR (EU) 2025/2621, Annex I. Certificate price estimates use current market trends and should be updated quarterly.

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Aluminium Importer Budget (500 tonnes/year)

Aluminium is an Annex II sector under Regulation 2023/956 Article 7(1). Only direct emissions are chargeable. Indirect emissions (from electricity) are reported but excluded from the cost calculation.

Year	Liable emissions	Est. price	Annual cost
2026	32.5 tCO₂	€75	~€2,400
2027	65 tCO₂	€80	~€5,200
2028	130 tCO₂	€85	~€11,100
2029	292.5 tCO₂	€90	~€26,300
2030	630.5 tCO₂	€95	~€59,900
2034	1,300 tCO₂	€100	~€130,000

The indirect exemption matters here. If indirect emissions were included, a coal-powered aluminium plant would pay 5-10× more.

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Cement Importer Budget (2,000 tonnes/year)

Cement includes both direct and indirect emissions in the chargeable calculation — it's not in Annex II.

Year	Liable emissions	Est. price	Annual cost
2026	35 tCO₂	€75	~€2,600
2027	70 tCO₂	€80	~€5,600
2028	140 tCO₂	€85	~€11,900
2029	315 tCO₂	€90	~€28,400
2030	679 tCO₂	€95	~€64,500
2034	1,400 tCO₂	€100	~€140,000

Source: IR (EU) 2025/2621 — Cement clinker benchmark 0.666 tCO₂e/t

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The 2029 Cliff: Budget for This

The jump between 2028 and 2029 is the sharpest:

• 2028: 10% liable
• 2029: 22.5% liable

That's a 125% increase in a single year.

What to do	When	Why
Start reducing emissions now	2026–2027	Gives you a lower baseline before the cliff
Negotiate CBAM into contracts	2026–2027	Pass costs to customers gradually
Track carbon price deductions	2026	Every euro you've already paid is a euro saved
Model different ETS scenarios	2026	Know what €120/tCO₂ does to your numbers

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5-Year Budget Template

Here's a blank template. Fill it in for your numbers.

Year	Volume (t)	tCO₂/t	Total tCO₂	Liable share	Liable tCO₂	Est. price	Cost	Deduction	Net cost
2026	___	___	___	2.5%	___	€75	€___	€___	€___
2027	___	___	___	5%	___	€80	€___	€___	€___
2028	___	___	___	10%	___	€85	€___	€___	€___
2029	___	___	___	22.5%	___	€90	€___	€___	€___
2030	___	___	___	48.5%	___	€95	€___	€___	€___

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Price Scenarios: What If ETS Spikes?

EU ETS prices are volatile. Here's how different prices affect a steel importer (1,000t BF-BOF):

Scenario	2026 cost	2030 cost	2034 cost
Low (€60)	~€2,900	~€70,200	~€114,000
Base (€80)	~€3,800	~€93,600	~€152,000
High (€120)	~€5,700	~€140,300	~€228,000
Very high (€150)	~€7,100	~€175,400	~€285,000

Budget recommendation: use the high scenario (€120/tCO₂). You'll either be right or pleasantly surprised. Try the CBAM calculator to model your own ETS price scenarios.

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When You Actually Pay

Date	Event
Feb 1, 2027	Certificate sales start
Quarterly in 2027	Purchase certificates for 2026 imports
Sep 30, 2027	First annual declaration due

You don't pay anything in 2026. The first payments happen in 2027. But the costs are based on 2026 imports.

For a detailed breakdown of how the certificate price is calculated and how the phase-in factor works, see our CBAM certificate cost guide.

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Key Takeaways

• Your 2026 cost is not your real cost. Budget using 2029–2030 numbers.
• The 2029 cliff (125% jump) is the biggest single-year increase.
• Steel BF-BOF importers pay 3× more than EAF importers at every stage.
• Aluminium importers benefit from the Annex II indirect exemption.
• Budget using €120/tCO₂ for safety margin.
• Track certificate prices quarterly — they change every 3 months.

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Budget Accurately with CbamTrack

CbamTrack shows your costs in real time — current year and projected.

• Live ETS price feed
• 5-year cost projection by sector
• Scenario modeling (low, base, high)
• Sector-specific benchmarks
• PDF budget reports for your finance team

Start free. No credit card required.

Sign up at cbamtrack.com/signup — or compare our plans to see which fits your import volume.

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FAQs

How much will CBAM cost me in 2026?

For a typical steel importer (1,000t BF-BOF), about €3,600. For aluminium (500t), about €2,400. For cement (2,000t), about €2,600. These numbers grow 40× by 2034 as free allocation phases out.

When do I pay CBAM?

Certificate sales start February 1, 2027. You purchase certificates quarterly in 2027 to cover your 2026 imports. The first annual declaration is due September 30, 2027.

What's the CBAM phase-in factor?

It's the percentage of free allocation that offsets your emissions liability. In 2026 it's 97.5% (you pay for 2.5%). By 2034 it's 0% (you pay for 100%). Source: Regulation (EU) 2023/956, Annex VIII.

Can I deduct carbon price paid in my country?

Yes. If you've paid a carbon tax or ETS in your country, that amount can be deducted from your CBAM obligation. You need official documentation.

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Last updated: July 2026 | Sources: EU Regulation 2023/956, CBAM Certificate Price Publication (April 7, 2026), EU ETS Auction Data, IR (EU) 2025/2621