CBAM quarterly certificate holding from 2027: how much cash it ties up (calculator)

From 2027, an authorised CBAM declarant must hold in its CBAM registry account, at the end of each quarter, certificates for at least 50% of the emissions embedded in everything it has imported since 1 January. Those emissions are counted either with default values without the mark-up or with the certificates it surrendered for the preceding year, and in both cases the free-allocation adjustment is taken off. It is cash paid months before the annual declaration: with 2,000 t of Chinese welded tube a year at the default value, about €176,869 on 31 December 2027.

Calculate your holding

What the rule says

The rule is Article 22(2) of Regulation (EU) 2023/956, as worded by Regulation (EU) 2025/2083: “From 2027, the authorised CBAM declarant shall ensure that the number of CBAM certificates on its account in the CBAM registry at the end of each quarter corresponds to at least 50 % of the embedded emissions in all goods it has imported since the beginning of the calendar year”.

• Every quarter, cumulative. It is checked on 31 March, 30 June, 30 September and 31 December, with everything imported since January. The count starts again each year.
• It is not the surrender. Certificates are surrendered once a year, with the declaration, by 30 September of the following year (Article 22(1)). The holding makes you buy earlier: half of them on the account while you import.
• From 2027. There is no quarterly holding in 2026. 2026 imports are paid in full on 30 September 2027, and certificates go on sale on 1 February 2027.

Two ways to count the emissions

The article lets the declarant choose the reference:

• (a) Default values without the mark-up of point 4.1 of Annex IV. For Chinese welded tube (CN 7306), 2.149 certificates per tonne in 2027, with the adjustment already taken off.
• (b) The certificates surrendered for the preceding year, provided the customs declaration refers to the same goods by CN code and country of origin as the CBAM declaration submitted in the previous year.

Both take into account the free-allocation adjustment of Article 31. That is why the holding weighs mostly on what sits above the reference: the less free allocation is left, the higher it goes. For the same tube, the base per tonne goes from 2.149 in 2027 to 2.797 in 2030 (inferred from the CBAM factors of Directive (EU) 2023/959, with today’s benchmarks).

In 2027 only (a) applies. (b) requires a CBAM declaration submitted in the previous year, and the first one, for 2026 imports, is submitted in 2027. So the 2027 holding is counted at the default value even if your supplier is verified, and (b) comes in from 2028: the 2028 holding refers to the declaration submitted in 2027, which covers 2026. This is our reading of the article, which does not spell out the arithmetic; an implementing act may. How (b) is applied is our reading too: the certificates per tonne in that declaration, applied to what you import this year.

An example: 2,000 t of welded tube

A distributor imports 500 t of Chinese welded tube every quarter. With the certificate at €82.32 (the official Q3-2026 price, held flat):

• In 2027, verified or not, (a) applies. On 31 March it must hold 537 certificates, about €44,217; on 31 December, 2,149, about €176,869.
• In 2028, if it declared 2026 at the default value, (a) still applies: 2,223 certificates on 31 December, about €183,006.
• In 2028, if it declared 2026 with the verified figure of a factory and its steel plant (1.7 t of CO₂ per tonne, an example), reference (b) brings the December holding down to 246 certificates, about €20,273.

The difference in 2028, about €162,732 at year end, is cash that is not tied up. It depends on the 2026 figure, which is being measured now. The figures are illustrative; yours come from the calculator above.

If you cross 50 t mid-year

An importer that exceeds the 50 t net-mass threshold during the year meets the holding by the end of the quarter following the one in which it crossed (Article 22(2a)). How the threshold adds up is in the CBAM 50-tonne threshold guide.

Certificates you hold too many of

• Repurchase. The Commission repurchases excess certificates through the common central platform on a request made by 31 October of the year in which certificates were surrendered (Article 23(1)).
• Capped. At most, the number the declarant had to buy under the quarterly holding that year (Article 23(2)).
• If you end up not crossing the threshold, all the certificates bought in expectation of crossing it are repurchased.
• 2026 ones only in 2027. Certificates bought in 2027 for 2026 emissions can only be repurchased in 2027 (Article 23(2a)).

What lowers the holding

Two things: importing fewer tonnes than expected or, from 2028, having submitted the year before a declaration with the supplier’s verified figure instead of the default value. For the 2028 holding, that is the declaration for 2026 imports. The second depends on your Chinese factory having a verified emissions report and, for products like tube, on its steel plant having one too, because most of the CO₂ is in the steel it buys. What you pay each year in each case is in the CBAM cost per tonne guide and the savings calculator; how your factory gets the figure, on HeavyDeals’ CBAM page, and what to ask it in writing, in the Chinese supplier letter.

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 27 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.