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. They must manage them actively throughout the year — purchasing at the right time, holding the right amount each quarter, and selling back any excess before the deadline. Understanding this process helps you negotiate better supply contracts, provide data at the right time, and position yourself as a compliance partner rather than just a commodity supplier.

The certificate timeline — key dates for 2027

• 1 February 2027 — Certificates go on sale. The CBAM registry opens for certificate purchases. Buyers can begin purchasing from this date.
• End of each calendar quarter — 50% holding requirement. At the end of Q1, Q2, Q3, and Q4 of 2027, each authorised declarant must hold CBAM certificates equal to at least 50% of their estimated total annual CBAM liability. If they hold less, the EU competent authority can require additional purchases or impose corrective measures.
• 31 October 2027 — Buyback deadline. Buyers can sell back to the EU authority up to 50% of the certificates they purchased during 2027, at the price they paid. This is the only mechanism for recovering over-purchased certificates — after this date, no buyback is available.
• 31 May 2028 — Final surrender deadline. All certificates equal to the total actual embedded CO₂e of 2027 imports must be surrendered by this date. This is the definitive settlement.
• Post-deadline — Cancellation. Any certificates not surrendered by 31 May 2028 are cancelled. They cannot be rolled forward to 2028 or used in any future year.

What the 50% quarterly requirement means in practice

This is the most misunderstood aspect of CBAM certificate management. It requires your buyer to forecast their annual import volumes — and the associated certificate obligation — before the year begins.

Consider a buyer importing 25,000 tonnes of your steel annually with a verified SEE of 1.615 tCO₂e/t. Their estimated 2027 certificate obligation is approximately 633 certificates (at 10% CBAM phase-in factor). By the end of Q1 2027 — March 31 — they must already hold certificates worth at least 50% of that total: approximately 317 certificates.

If they are using EU default values instead of your verified data, their estimated obligation is much higher — approximately 2,760 certificates at the 2027 phase-in factor — and their Q1 holding requirement is correspondingly larger. The cash flow difference between using verified data and default values is significant from the first quarter of the year.

How your verified data directly helps your buyer's cash flow

The earlier in the year you provide your verified SEE data, the more accurately your buyer can plan their certificate purchases. Late or inaccurate data forces buyers to over-purchase as a buffer against uncertainty — certificates tied up unnecessarily that could otherwise be deployed elsewhere.

Providing your verified Operator's Summary Emissions Report (Document B) to your EU buyer before 1 February 2027 — the date certificate sales open — gives them the maximum possible advantage in planning their quarterly purchases.

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 — by 1 December each year for the previous reporting year. This gives your buyer two months to plan before certificate sales open.
• 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.

Why this matters for your commercial relationship

A buyer who has to over-purchase certificates because they lack your verified data — or who faces a penalty because your data arrived too late — will remember that experience. A buyer who consistently receives accurate, timely emissions data from you, enabling precise quarterly planning and optimal certificate management, has a compelling reason to maintain and grow the supply relationship.

Certificate management is not just your buyer's compliance headache. It is your competitive advantage.

Generate your Operator's Summary Emissions Report (Document B) using DeCarbonPro and deliver it to your EU buyer before the Q1 2027 certificate purchase deadline.