CBAM

There is no "CBAM tax": why the wording matters for exporters

Calling CBAM a tax hides the part that exporters can influence. How it really works, and why precise wording helps you in negotiations with EU customers.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 14 October 2026 · Sources last checked 16 October 2026

What the mechanism asks of an importer

Each year the authorised CBAM declarant reports the quantity of goods imported, their embedded emissions and the corresponding number of CBAM certificates, and then surrenders those certificates. One certificate corresponds to one tonne of embedded CO2 equivalent.

Where the price comes from

The price of a CBAM certificate follows the price of emissions allowances in the EU emissions trading system. For 2026 imports, the price is calculated quarterly, after the quarter ends; the Commission published the price for the third quarter of 2026 on 5 October. Sales of certificates for 2026 emissions begin on 1 February 2027, and the first annual declaration and surrender is due on 30 September 2027.

Why the wording matters for you

1. The amount follows emissions. In everyday use, a tax is a rate applied to a value. Under CBAM, the number of certificates depends on the embedded emissions of the goods. Those emissions are calculated either on EU default values or on actual data from the installation, and actual data must be verified.
2. It can be reduced. A carbon price effectively paid in a third country can reduce the certificates to surrender, after any rebate or compensation is taken into account. For declarations made on default values, a reduction can only be claimed through the applicable yearly default carbon price.
3. The timing is operational. The simplification reduced the share of estimated embedded emissions that a declarant must cover with certificates each quarter, from 80% to 50%. That changes when your customer needs to buy, and so when they need your data.

Use the precise words with your customers

• "Embedded emissions" and "installation": these are what you can measure and prove.
• "Default values" and "verified actual data": this is the choice that sets how much your customer has to cover.
• "Authorised declarant" and "certificates": this tells your customer you understand where the obligation sits and what they need from you.

None of this makes CBAM cheap. It makes it manageable, because the part you influence is the data. The free CBAM Compass Report estimates your readiness and the cost per tonne your buyers may face on default values.