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CBAM Steel Quarterly: 2026 Calculator and Reporting Workflow

EU CBAM moved to the definitive phase January 1 2026. Steel importers buy CBAM certificates quarterly priced at the prior week's EU ETS average. Here is the computation, the embedded-emissions data path, and the operational workflow.

Updated 2026-06-185 min read
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CBAM Steel Quarterly: 2026 Calculator and Reporting Workflow

The EU Carbon Border Adjustment Mechanism (CBAM) moved into its definitive phase on January 1 2026. The transitional phase that ran from October 2023 was reporting-only. The definitive phase requires importers of CBAM-scope goods into the EU to buy CBAM certificates matching the embedded carbon emissions of their imports, priced at the EU Emissions Trading System (ETS) market rate.

For steel importers (HS chapter 72 and selected chapter 73 lines), CBAM is now a quarterly cash cost on top of the existing tariff stack. This guide covers the scope, the quarterly cadence, the embedded-emissions data path, the price mechanics, and a worked example for a typical Indian-origin steel shipment into Germany.

Scope in 2026

CBAM covers six product categories as of mid-2026:

  • Iron and steel: all of chapter 72 plus HTS 7301, 7302, 7308 (structures), 7311, 7318 (screws, bolts), 7326. The 2025 expansion proclamation added the structures and fastener categories.
  • Aluminum: chapter 76 plus selected derivative lines in chapter 76 only at this stage. Aluminum derivatives in chapter 84 to 94 are on the 2027 expansion roadmap.
  • Cement: HS 2523.
  • Fertilizer: HS 28 and 31 covering specific lines.
  • Electricity: when imported via cross-border interconnect.
  • Hydrogen: HS 2804.10.

Plastics and chemicals are scheduled for the 2030 expansion.

Quarterly cadence

QuarterReporting periodReport dueCertificate purchase deadline
Q1 2026Jan to Mar 2026April 30 2026At report submission
Q2 2026Apr to Jun 2026July 31 2026At report submission
Q3 2026Jul to Sep 2026October 31 2026At report submission
Q4 2026Oct to Dec 2026January 31 2027At report submission
Annual reconciliationAll 2026May 31 2027Settles any adjustment

The quarterly reports are filed in the CBAM Registry portal accessible through national authorities. Each EU member state operates its own portal entrypoint into the central EU CBAM Registry.

Price mechanics

Each Friday the Commission publishes the prior week's average closing price of EU ETS allowances on the EEX exchange. CBAM certificates for the following week are sold at that price. As of June 2026 the running price is approximately €88 per tCO2e, having fluctuated between €75 and €105 over the first half of 2026.

Importers buy certificates in advance of or at the time of customs entry. The certificate count required equals the embedded emissions of the import (in tCO2e) minus any verified carbon price already paid in the country of origin.

Embedded emissions data

For each CBAM-scope shipment, the importer must determine the embedded emissions in tCO2e. There are three data paths:

Path A: Supplier-specific data. The producer in the country of origin provides verified embedded emissions data per tonne of product. Verification by an EU-accredited verifier is required. Once verified, the data is good for one year. This produces the lowest CBAM cost where the supplier has invested in lower-emission production.

Path B: Default values. The Commission publishes country-and-product-specific default values. These are deliberately conservative (high) to incentivize Path A. Typical 2026 default values per tonne of crude steel:

OrigintCO2e per tonne (steel)
Russia2.85
India2.62
China2.48
Turkey1.95
Korea1.78
Japan1.65
US1.42
Canada (hydropower BF)0.82

Path C: Other suitable data. Limited acceptable data sources (e.g., industry-average studies). Rarely used in practice.

Worked example: Indian hot-rolled coil into Germany

10,000 tonnes of Indian-origin hot-rolled coil (HTS 7208.39), shipment value €4.2M, embedded emissions data from supplier verified.

Supplier-verified emissions: 2.18 tCO2e per tonne (lower than the 2.62 default because the supplier uses some scrap and a more efficient blast furnace).

Total embedded emissions: 10,000 x 2.18 = 21,800 tCO2e.

Carbon price paid in India: India has a domestic carbon market under the 2024 Carbon Credit Trading Scheme. Average 2026 price approximately €2.10 per tCO2e. Deductible against CBAM.

ItemComputationAmount
Embedded emissions10,000 x 2.1821,800 tCO2e
EU ETS reference price (June 2026 average)€88 / tCO2e
Gross CBAM cost21,800 x €88€1,918,400
India carbon price credit21,800 x €2.10€45,780
Net CBAM certificate costgross minus credit€1,872,620
Per-tonne CBAM€1,872,620 / 10,000€187 / tonne
Per-tonne CBAM as percent of invoice€187 / €42044.6 percent

Effective CBAM ad valorem 44.6 percent of invoice value. Stacks on top of EU MFN duty (0 percent for most chapter 72), TARIC safeguard quotas if applicable, and any EU antidumping or countervailing duty (India steel pipe has active orders).

Using default values vs. supplier data

Same shipment, supplier did not provide verified data. Default value 2.62 tCO2e per tonne:

ItemComputationAmount
Embedded emissions10,000 x 2.6226,200 tCO2e
Gross CBAM cost26,200 x €88€2,305,600
India carbon price credit26,200 x €2.10€55,020
Net CBAM certificate cost€2,250,580

Default-value cost: €2.25M. Supplier-data cost: €1.87M. Difference: €378,000 per shipment, or €37.80 per tonne. The economic incentive to invest in supplier verification is real.

Carbon Leakage compensation

CBAM revenues do not flow to the EU general budget. They sit in a dedicated fund that is partially redirected back to EU steel producers as carbon leakage compensation. EU producers continue receiving free EU ETS allowances on a declining schedule. The free allocation phases out over the 2026 to 2034 period at 10 percent per year. By 2034 the EU steel sector operates under full ETS pricing with no free allocation.

For importers, this means the relative CBAM burden vs. EU domestic production is highest in early years (where EU producers still get some free allowance) and rises over time as the free allocation phases out.

Documentation

  • Verified embedded emissions report from the supplier (Path A) or use of published default values.
  • Quarterly CBAM declaration filed via the national CBAM Registry portal.
  • Proof of carbon price paid in the country of origin (for the credit).
  • Records retained for 4 years from the quarterly filing.

Run your CBAM steel entry now

The LandedFees calculator covers the CBAM definitive-phase math with current EU ETS reference prices, default values by country and product, the carbon-price credit logic, and the full stack with EU MFN, safeguard quotas, and antidumping where applicable. Useful for quoting EU customers and for sourcing decisions where CBAM materially shifts the lane economics.

Calculate a CBAM steel entry

Citations

Frequently asked questions

When did CBAM move to the definitive phase?

January 1 2026. The transitional phase ran from October 2023 through December 2025 with reporting only and no certificate purchase requirement. From January 2026, importers of CBAM-scope goods must buy CBAM certificates matching the embedded emissions of their imports.

What products are in CBAM scope?

Iron and steel (chapter 72 plus selected 73 lines), aluminum (chapter 76 plus selected derivative lines), cement (HS 2523), fertilizer (HS 31), electricity, and hydrogen. The 2026 expansion added selected downstream steel and aluminum derivatives. Plastics and chemicals are on the 2030 expansion roadmap.

How is the CBAM price set?

Each Friday, the European Commission publishes the average closing price of EU ETS allowances from the previous calendar week. CBAM certificates for the next week are priced at that rate. Importers buy certificates equal in number to the tCO2e embedded emissions of their imports.

What if my supplier does not provide embedded emissions data?

Default values apply. The Commission publishes country-and-product-specific default values that are deliberately conservative (high). Using default values increases the certificate count required. Real supplier-specific data is almost always cheaper if the supplier can produce it.

When are quarterly reports due?

Q1 2026 report is due by April 30 2026. Q2 by July 31. Q3 by October 31. Q4 by January 31 2027. Annual reconciliation by May 31 of the following year.

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