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

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. 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

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.

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.

Which emissions figure goes into that calculation is where your data lands. Article 22(2)(a) sends a buyer with no verified figure to the Annex IV default value — the exporting-country average, though for this purpose without the point 4.1 mark-up. A verified SEE below that default lowers the year-to-date total, and therefore the quarterly holding, from the first quarter onwards. The size of the gap is a calculation on your own CN code, country and volumes rather than a number that can be quoted in the abstract — the calculator on this site works it through.

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.