Keldrion

Keldrion · Regulatory technology

CBAM certificate cost estimator

Pick the CN code of the good and the country of origin, and the estimator takes the Commission’s published default value for that pair, adds the Annex I mark-up, deducts the free-allocation adjustment built from the CBAM benchmark and the CBAM factor, and prices the certificates at the Commission’s published price.

The estimate

Loading the Commission default values...

Country of origin under the non-preferential rules of origin, not the country of export. A country the Commission does not list separately falls back to “Other countries and territories”.

Pick a country and a CN code to fill the Commission default.

Data basis

Defaults carry the +10% mark-up for 2026; the free-allocation adjustment is deducted from the result.

Import year

Free allocation still granted: 97.5% - 2.5% of benchmark-level emissions requires certificates. Article 10a(1a), ETS Directive.

Quarter of importation

2026 prices are quarterly averages of EU ETS auction clearing prices; the fourth is due 4 Jan 2027.

Prefilled with the Commission CBAM price, Q3 2026. Published on the Commission's price page; certificates first go on sale on 1 February 2027. Source ·

Pick a country, a CN code and a net mass to see the estimate.

This is arithmetic, not a filing. It does not deduct a carbon price paid in the country of origin (Article 9: the implementing act is still a draft, and no per-country default carbon prices are published), it does not apply the 50-tonne de minimis line, and it uses the CN-level default CBAM benchmark rather than an installation’s own process and precursor free allocation. Default values come from the default values act and the benchmarks act; the mark-up, the CBAM factor and the price each come from the provisions cited above. Read it with the Commission’s guidance before relying on it.

Default values and benchmarks: Commission workbooks, transcribed from Implementing Regulation (EU) 2025/2621 and Implementing Regulation (EU) 2025/2620. Certificate price: the Commission’s price page. Live EU ETS spot price: OilPriceAPI · EU_CARBON_EUR · offered only as a labelled proxy.

How this is calculated

certificates = tonnes × max(0, intensity − benchmark × CBAM factor × correction factor)
cost = certificates × certificate price

The CN code and the country of origin. The CN code is the customs classification of the good; the country of origin is where it was produced, under the non-preferential rules of origin - not where it was shipped from. Those two answers decide everything below, because the Commission publishes its figures against exactly that pair.

The intensity, and the mark-up. Intensity is the tonnes of CO₂e embedded in one tonne of the good. Use the installation’s verified figure if you have one, otherwise the Commission’s default value for your CN code and country. A declaration on default values carries the Annex I mark-up, applied to the Commission’s “total emissions” column: +10% for 2026, +20% for 2027, +30% from 2028, and a flat +1% for fertilisers. Verified actual data carries none.

The benchmark, and the letter in brackets. The second table involved is the CBAM benchmark, set per CN code and per production route in Implementing Regulation (EU) 2025/2620. The route is not a free choice: for each country and CN code the Commission’s default-value table names it, in a last column headed “Underlying production route determining CBAM BM”, with a letter for each country and CN code. (K) is primary aluminium and (L) secondary; (A) and (B) are grey and white clinker; (C) and (F) are blast-furnace steel, (D) and (G) direct-reduced iron, (E) and (H) scrap, and (J) high-alloy steel. The letter is not a number - it selects which benchmark applies. So the benchmark is not country-specific (the country’s row only names the route), and it is not one number per route either. On the (K) route alone it runs:

CN codeGoodBenchmark (K)
7601Unwrought aluminium1.423
7604 10 10, 7604 29 10Bars and rods1.485
7604 10 90, 7604 21 00, 7604 29 90Profiles1.493
7603, 7616 99 10Powders, castings1.506
7611 00 00, 7612, 7613 00 00Reservoirs, casks, containers1.594
7607Foil1.599

Figures in tCO₂e per tonne, from the Commission’s benchmark workbook. Where an aggregated category names two routes - a steel heading whose row says (C)/(F) - the estimator asks which route the goods were made by rather than choosing for you.

The CBAM factor. Article 10a(1a) of the ETS Directive expresses the factor as the free allocation that is still granted to EU producers: 97.5% in 2026, 95% in 2027, 90% in 2028, 77.5% in 2029, 51.5% in 2030, 39% in 2031, 26.5% in 2032 and 14% in 2033, and none from 2034. It multiplies the benchmark, not your emissions. The familiar 2.5% figure is its complement - the share of embedded emissions requiring certificates when emissions sit exactly on the benchmark - and it is not a number to multiply embedded emissions by.

The correction factor. 100% for 2026 to 2030, fixed by Commission Implementing Decision (EU) 2026/1862. It has not been determined beyond 2030, where the estimator assumes 100% and says so.

The floor. The deduction cannot produce a credit. If the benchmark times the factor is larger than the intensity, the certificate count is zero and nothing is due for that good - which happens for 171 of the country-and-code pairs in the Commission’s table in 2026. Calcined clay (CN 2507 00 80 80) from Albania is one: a 0.28 default becomes 0.308 with the mark-up, against a benchmark of 0.666 × 97.5% = 0.649.

The certificate price. The price the Commission publishes, which is the volume-weighted average of EU ETS auction clearing prices: quarterly for 2026, applied to the quarter the goods were imported in, and weekly from 2027. Certificates first go on sale on 1 February 2027, so a 2026 figure is a projection at a known price; the fourth 2026 price is due on 4 January 2027.

One consignment, end to end. China, CN 7604 10 90 (aluminium profiles), one tonne, 2026 imports, at the Q1 2026 certificate price:

4.881 default × 1.10 mark-up = 5.3691 tCO₂e/t
route (K) → benchmark 1.493 × 97.5% factor × 100% correction = 1.4557
5.3691 − 1.4557 = 3.9134 tCO₂e/t
3.9134 × €75.36 = €294.92 per tonne

The bars code 7604 10 10 takes the 1.485 benchmark and gives €295.50. The same unwrought aluminium (7601) imported from Algeria is a (L) row: its default is 0.36 and its benchmark 0.091, so the tonne carries €23.16 rather than €144.13.

Import yearCBAM factorCertificate share
202697.5%2.5%
202795%5%
202890%10%
202977.5%22.5%
203051.5%48.5%
203139%61%
203226.5%73.5%
203314%86%
20340%100%

The CBAM factor is the free allocation still granted to EU producers; the certificate share is the complement, and applies to benchmark-level emissions only.

Pending, not law: the Phase-5 proposal (COM(2026) 616) would slow this schedule from 2028 and stretch the phase-out toward 2038. The schedule above is the enacted one - re-checked on adoption.

Read the estimate with care

This is arithmetic, not a filing. It does not deduct a carbon price already paid in the country of origin: Article 9 allows that deduction, but its implementing act is still a draft, no per-country default carbon prices have been published, and it cannot take the number below zero. Nor does it track the 50-tonne de minimis line - which, once crossed, makes every tonne of that year liable, not just the excess. The regulation does both.

Indirect emissions are in scope for cement and fertilisers and, with one exception for agglomerated iron ores, out of scope for iron and steel, aluminium, hydrogen and electricity - so the intensity to use depends on the sector. On verified actual data the free-allocation adjustment is built from the installation’s own process benchmark and its precursors rather than the CN-level benchmark used here, which makes an actual-data result indicative rather than exact.

For the declaration itself - records per consignment, verified emissions, the deduction rules, and the export - Kaimeter exists. The primary sources are the regulation, the Commission’s CBAM legislation page and its guidance on the free-allocation adjustment.