CBAM Definitive Period: 2026 Declaration, Certificates and Worked Example

On 1 January 2026, CBAM moved from the transitional period to the definitive period. During the transitional period (October 2023 to December 2025), EU importers only submitted quarterly reports; now there is an annual declaration, and certificates must be bought and surrendered. The European Commission's Questions and Answers document of 15 October 2026 and the operator guidance documents published on 14 August 2026 are the most recent official sources this guide relies on.

This page summarises the timeline and the rules, then walks step by step through the embedded emissions and number of certificates for a producer in Türkiye exporting rebar to the EU. For the overall framework, see the main CBAM and Emissions Trading Guide.

Legal framework of the definitive period

The core text is Regulation (EU) 2023/956. It was simplified by Regulation (EU) 2025/2083 of 8 October 2025, whose publication the Commission announced on 20 October 2025. The Commission's legislation page lists the implementing acts that operate the definitive period as follows:

The implementing act on deducting the carbon price paid in the country of origin (Article 9) does not yet appear as adopted on this list (October 2026). The Commission writes that it plans to adopt it in 2026 and to clarify the rules before the first declarations.

The authorised CBAM declarant and the 50-tonne threshold

Since 1 January 2026, importing CBAM goods requires the status of authorised CBAM declarant. Applications are made to the national competent authority of the Member State where the importer is established. The obligation can be taken on by the importer or by an indirect customs representative; an importer established outside the EU must appoint an indirect customs representative.

The 2025 simplification replaced the per-consignment value exemption with a threshold of 50 tonnes of net mass per importer per year. An importer that imports no more than 50 tonnes in total in a calendar year across cement, iron and steel, aluminium and fertilisers has no obligation. Importers of hydrogen and electricity must be authorised in all cases. According to the Commission, the threshold exempts the majority of importers while keeping more than 99% of in-scope emissions in the system. According to DEHSt, Germany's CBAM authority, importers that applied by 31 March 2026 can continue importing above the threshold until their application is decided.

What this means for Turkish exporters: even if small buyers are exempt, EU customers buying regular tonnages will be well above the threshold, so data requests will continue.

Annual timeline

The certificate price is calculated as the volume-weighted average of EU ETS auction prices, quarterly for 2026 and weekly from 2027. Certificates bought for 2026 imports are priced at the price for the quarter in which the goods were imported. Certificates cannot be transferred to anyone else or sold; after declaration and surrender, a repurchase can be requested for certificates remaining in the account.

How is the number of certificates calculated?

The logic in the Commission's Questions and Answers document (question 3.7) for each CBAM good is:

Number of certificates = Quantity imported (t) × (Specific embedded emissions − Specific embedded free allocation) − Emissions corresponding to the carbon price effectively paid in the country of origin

If the result for a good is negative, it is taken as zero. The formula for the free allocation adjustment in the iron and steel guidance is:

Specific embedded free allocation (year) = CBAM factor (year) × Cross-sectoral correction factor (year) × CBAM benchmark

The CBAM factor is 97.5% for 2026 and 95% for 2027, and it decreases until 2034 (DEHSt). Where default values are used, the benchmark is taken from column B of 2025/2620, according to the production route shown for that country in the default values table. Where actual data are used, the process benchmarks in column A are combined with the installation's own precursor ratios.

Indirect emissions and precursors

Indirect (electricity-related) emissions are counted only for cement and fertilisers; for iron and steel, aluminium and hydrogen, only direct emissions are counted. The Commission's guidance also stresses that in CBAM the term "indirect emissions" refers only to electricity, and that heat is monitored on the direct emissions side. For precursors (for example pig iron or semi-finished products in steelmaking), if verified actual data cannot be obtained from the supplier, the default value of the supplier's country is used where that country is known, and the highest value in Annex IV where it is not; a mixed calculation combined with the installation's own process data is possible.

Worked example: a Turkish rebar exporter

Assumption (illustrative): In 2026, an EU importer imports 10,000 tonnes of ribbed reinforcing bar (CN 7214 20 00) from an installation in Türkiye. The quantity is illustrative. It is assumed that no carbon price is paid in Türkiye and that there is no Article 9 deduction (under the TR ETS, 2026 is a reporting-only year).

Scenario A: using default values

1. Türkiye default value: In the Commission's August 2026 information file, the Türkiye value for CN 7214 20 00 is 2.310 tCO₂e/t (direct only; production route indicator (C)).
2. 2026 mark-up (10%): 2.310 × 1.10 = 2.541 tCO₂e/t
3. Total embedded emissions: 10,000 t × 2.541 = 25,410 tCO₂e
4. Free allocation adjustment: In column B of 2025/2620, the benchmark for this CN code and route (C) is 1.364 tCO₂e/t. The cross-sectoral correction factor is taken as 1 (illustrative assumption), as in the example in the Commission's iron and steel guidance. 1.364 × 0.975 × 1 = 1.330 tCO₂e/t (rounded); for 10,000 t, 13,299 tCO₂e.
5. Certificates to surrender: 25,410 − 13,299 = 12,111 certificates (net 1.211 tCO₂e per tonne).

Scenario B: using verified actual data

Assume the same installation operates a scrap-based electric arc furnace route and its verified specific embedded emissions come to 0.70 tCO₂e/t (illustrative value).

1. Total embedded emissions: 10,000 t × 0.70 = 7,000 tCO₂e
2. Free allocation adjustment: When calculating with actual data, the blast furnace route benchmark used in the default scenario no longer applies; the process benchmarks in column A of 2025/2620 are combined with the installation's own route and precursor ratios. Assume the specific free allocation calculated from the installation's data is 0.45 tCO₂e/t (illustrative value): 0.45 × 0.975 × 1 = 0.439 tCO₂e/t; for 10,000 t, 4,388 tCO₂e.
3. Certificates to surrender: 7,000 − 4,388 = 2,612 certificates (net 0.261 tCO₂e per tonne).

Lessons from the example

• The default value determines not only the emissions but also which route is used to calculate free allocation. In the Commission's iron and steel guidance, indicator (C) denotes the blast furnace route; in this example, although the default scenario uses this route's higher benchmark, the default emissions with the 10% mark-up outweigh that advantage.
• With the mark-up rising to 20% in 2027 and 30% from 2028, the gap between default values and actual data for the same product will widen; as the CBAM factor falls, the free allocation adjustment will also shrink.
• The values in Scenario B are illustrative. The real difference depends on your installation's route, precursor supply and electricity source; for cement and fertilisers, indirect emissions are added as well.
• For some products there is no country-specific default value for Türkiye. In the August 2026 file, for example, the Türkiye row has no value for grey Portland cement (2523 29 00) or grey clinker; in that case the "other countries and territories" value applies, based on the average of the ten exporting countries with the highest intensity (1.440 tCO₂e/t for grey Portland cement, 1.584 tCO₂e/t with the 2026 mark-up).

Exchanging data with the importer

According to the Commission's Guidance Document 2, the producer monitors on a calendar-year basis, divides the emissions attributed to each production process by the activity level at year end to obtain specific embedded emissions, and passes these to its customers in an operator emissions report. The content of the report is standardised under Article 10 of the methodology regulation; the Commission's Excel tool is not mandatory but is recommended, and it brings together on a single page the summary the importer needs.

There are two ways to transmit the data:

• CBAM Registry (O3CI module): The producer uploads installation data once and, after verification, shares it with all importers. Each importer sees only the summary it needs, and confidential details are protected. Registration is voluntary for now, but the Commission strongly recommends it.
• Transmission outside the Registry: Using the same template, separately for each customer. In this case the importer must request and keep the full emissions report and verification report from you, and must upload this information to the Registry itself when declaring.

In practice, an EU customer will ask for: installation identity and reporting period; specific direct (and, where relevant, indirect) embedded emissions per CN code; production route and product-specific parameters; information on precursors used; specific embedded free allocation; any carbon price paid; and the verification report. We share our experience of setting up the process on the supplier side in the post CBAM readiness: the supplier's perspective.

Verification

• Verification is required only for actual data; default values are not verified.
• The verifier must hold CBAM accreditation for the relevant sector from a national accreditation body in the EU. Accredited verifiers will be listed in the CBAM Registry, and the Commission will publish the list regularly.
• The Commission expects the first accreditations to be granted around September 2026 and verification work to take place in early 2027. Verification cannot be carried out before accreditation, but you can already make contact with verifiers going through the accreditation process.
• Legal responsibility for the declaration and the verification report it contains lies with the importer; if incorrect data affect the number of certificates, the importer may face penalties. For this reason, EU customers may prefer to switch to default values rather than accept unverified data.

An installation covered by the TR ETS will also need verification by a verifier accredited by TÜRKAK, the Turkish Accreditation Agency. The two verification timelines overlap in the first half of 2027; for details, see the Turkish Emissions Trading System guide.

Penalties and risks

According to DEHSt's summary, failing to surrender certificates in full, and importing above the threshold without authorisation or without applying in time, are subject to penalties. Artificially splitting imports to stay below the threshold may be treated as a serious infringement; repeated infringements can lead to the authorisation being withdrawn. These risks belong to the importer, but they feed directly into supplier selection: a producer that cannot provide verified data means a higher and less predictable obligation for its buyer.

Open issues as of October 2026

• Article 9 implementing act: How the carbon price paid in the country of origin will be evidenced and deducted is not yet finalised; the Commission is also considering publishing default carbon prices by country.
• Benchmark update: CBAM benchmarks updated in line with the 2026-2030 EU ETS benchmarks are expected to apply from 1 January 2027.
• Proposal to extend the scope: The amendment proposed by the Commission on 17 December 2025, covering downstream goods and anti-circumvention measures, is being negotiated by the EU co-legislators.
• Review of default values: According to the Commission's guidance, the default values regulation will be revised by 2027 at the latest.

If you want to build a verification-ready CBAM emissions report based on actual data for your exports to the EU, and to organise the data flow with your customers, see our CBAM readiness service. If your installation is covered by the TR ETS, you can design the monitoring structure for both systems under one roof with Alalëa; our ETS readiness page can also help.