CBAM Certificates in 2027: What Your EU Buyer Must Do and How You Help Them

By Ahmed Medhat · Published9 May 2026 · Updated 9 September 2026

CBAM Certificates in 2027: What Your EU Buyer Must Do and How You Help Them

Your EU buyer does not just surrender CBAM certificates once a year. Through the year they buy certificates, hold the required amount at each quarter's end, and can ask for excess certificates to be repurchased. Knowing this process tells you when your buyer needs your data.

The certificate timeline — key dates for 2027

• 1 February 2027 — Certificates go on sale. From this date each Member State sells CBAM certificates on a common central platform to the authorised declarants established in it (Article 20(1)).
• End of each calendar quarter — 50% holding requirement. Article 22(2), which applies from 2027: at the end of each quarter the authorised declarant must hold certificates corresponding to at least 50% of the embedded emissions in all goods it has imported since the beginning of the calendar year — the year so far, not a forecast of the whole year. The emissions are taken either from Annex IV default values without the Annex IV point 4.1 mark-up, or from the number of certificates surrendered for the preceding year where the customs declaration covers the same CN codes and countries of origin; the Article 31 free-allocation adjustment is taken into account. If they hold less, the competent authority notifies them and they have one month to top up (Article 22(3)).
• 31 October 2027 — Buyback deadline. Article 23(1): the repurchase request goes in by 31 October of each year in which certificates were surrendered, and the price is the price the declarant paid. The limit is not a flat share of what was bought: Article 23(2) caps repurchase at the total number of certificates the declarant had an obligation to purchase under Article 22(2) during the calendar year of purchase. Two riders matter — a declarant who bought on an expectation of crossing the single mass-based threshold and did not cross it has all of those certificates repurchased on request (Article 23(2)), and certificates bought in 2027 for 2026 emissions may only be repurchased in 2027 (Article 23(2a)).
• 30 September 2028 — Final surrender deadline. Article 22(1): by 30 September of each year the authorised declarant surrenders the number of certificates corresponding to the embedded emissions declared for the preceding calendar year. For 2027 imports that date is 30 September 2028. This is the definitive settlement.
• 1 November — Cancellation. Article 24(1): on 1 November of each year the Commission cancels, without compensation, any certificates purchased during the year before the previous calendar year that are still in the account. Cancellation is dated and backward-looking; it is not "whatever was left after the surrender deadline". Article 24(2) fixes the first one: on 1 November 2027 the Commission cancels any certificates purchased in respect of 2026 embedded emissions.

What the 50% quarterly requirement means in practice

It does not ask your buyer to forecast the year; it is measured against what has actually been imported so far.

Read the rule in the order the act writes it. At 31 March 2027 the quantity that matters is the embedded emissions of what the buyer has already imported since 1 January 2027 — not the year it expects to have. Half of that, adjusted for free allocation under Article 31, is what must be sitting in the account. The obligation then grows quarter by quarter as the year-to-date total grows, which is why it is a cash-flow question rather than a single January decision.

The emissions figure in that calculation is not the buyer's declared figure. Article 22(2) offers two measures: (a) the Annex IV default value without the point 4.1 mark-up, or (b) the number of certificates surrendered for the preceding year, where the customs declaration covers the same goods by CN code and country of origin. Your verified data reaches the quarterly holding only through (b), once your buyer has surrendered for a year on your verified figures.

Where your verified data counts

Your verified SEE sets the embedded emissions your buyer declares where it uses actual emissions, and so the certificates it surrenders (Articles 6 and 22(1)). For 2026 imports, the declaration and the surrender are both due by 30 September 2027, so that is the date by which your buyer needs your verified 2026 data.

What to include in your supply contract

Exporters who understand the certificate management timeline can build provisions into supply agreements that protect both parties:

• Data delivery commitment: Include a clause committing you to provide verified SEE data — your Operator's Summary Emissions Report — for each reporting year by an agreed date ahead of 30 September of the following year, when your buyer declares and surrenders.
• Process change notification: Include a commitment to notify your buyer if your production processes change materially during the year in a way that could affect your SEE figure.
• Monitoring plan reference: Reference your monitoring plan version and status in the contract. This gives your buyer assurance that your data is prepared under a documented methodology.

Generate your Operator's Summary Emissions Report (Document B) using DeCarbonPro and deliver it to your EU buyer ahead of its 30 September 2027 declaration.