EU CBAM: First Price Announcement and CBAM planning strategies

The first Price Annoucement has been confirmed for the EU’s Carbon Border Adjustment Mechanism (CBAM) framework for Quarter 1, in April 2026. This marks a significant step in the EU’s CBAM Definitive Phase, which started at the beginning of the year, and for the first time provides a concrete reference point, and a number, for carbon cost calculations.

Early planning and thorough audits up the supply chain are key for efficient CBAM planning strategies. It is clear that relying on combined default values for third party exporters will add significant extra CBAM costs to products imported into the EU, in comparison to the use of fully verified CBAM data values. There is still time to catch up to take advantage of the benefits of not relying on default CBAM values, and prepare for third-party supplier compliance and verified CBAM data. 

This CMS Legal Update is part of our CBAM series and summarises the main take-aways these new developments mean for those affected by EU CBAM.

Our CBAM series has covered the various recent developments for EU CBAM at the end of last year, see here and here.

Scope

The EU’s Carbon Border Adjustment Mechanism (CBAM) introduces a charge on in-scope carbon intensive products imported into the EU, to level the playing field with the relevant internal EU Emissions Trading System (ETS), and prevent carbon leakage (i.e. EU manufacturers moving production outside the EU to avoid ETS). Goods primarily in the sectors of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen are currently affected. CBAM applies to both raw materials and certain downstream, semi-finished and finished products, identified by a product’s specific international ‘import’ code.

In December 2025, the EC published a series of implementing acts providing significant details on CBAM operations. It also proposed amendments to the original CBAM scope and to close loopholes/prevent circumvention. Key proposals include expanding the scope of CBAM to include downstream steel and aluminium intensive products from 1 January 2028; enhancing reporting requirements for better traceability of CBAM goods and addressing emission intensity misdeclarations; and providing the EC with powers to tackle evidence-based abuses circumventing CBAM related financial responsibilities.

Definitive Phase

Following a two-year Transitional Phase, the EU’s CBAM Definitive Phase is now fully applicable: while this phase commenced from 1 January 2026, a grace period was permitted at EU borders until the end of March. Since 1 April however, only authorised CBAM declarants are permitted to bring in-scope goods into the EU. Declarants must report the amount of carbon emitted during production of the imported goods, maintain records and (from next year) purchase CBAM certificates corresponding to the embedded emissions.

First Quarterly Price Published and Quarterly Timetable

In March the EC announced the timetable for publication of the quarterly price of CBAM certificates. On 7 April 2026, the EC published the first quarterly price for CBAM certificates at €75.36 per tonne of CO2, marking the beginning of the CBAM's definitive pricing regime. This is based on the average EU ETS price over the last three months and serves as the benchmark for future CBAM prices. 

This is important because it marks the first time that CBAM requirements properly translate into financial exposure, and defines exactly how much importers will pay on carbon-intensive product imports. During the Transitional Phase, companies were required to report embedded emissions in reported goods, and while significant, this did not impose direct financial obligations. Although companies will only require to purchase CBAM certificates from 2027 onwards, this first CBAM price is highly relevant now as it will affect commercial decisions in a number of ways: 

• providing a concrete reference point for carbon cost calculations on imports;
• supporting investment and sourcing decisions; and
• enabling margin and pricing impact assessments.

During 2026, the EC will publish four quarterly CBAM prices, each calculated during the first calendar week after the relevant quarter ends. The Q1 2026 price of €75.36/tn CO2 applies to certificates covering emissions embedded in CBAM goods imported during that quarter. The remaining publication dates are 6 July 2026 (Q2), 5 October 2026 (Q3), and 4 January 2027 (Q4). From 2027 onwards, pricing will shift to a weekly cycle, and all CBAM certificates will be purchased through a common central platform beginning in February 2027. 

Verified data vs. Default values

It is clear that relying on combined default values issued by the EC for third party exporters will add significant extra CBAM costs to products imported into the EU, in comparison to the use of fully verified CBAM data. Early planning and thorough audits up the supply chain are key. Ultimately, taking early action to understand and comply with CBAM going forward will lower associated costs imposed in the long run. 

Where EU importers/third party exporters have not yet prepared for CBAM, there is still time to catch up before the initial deadlines apply, and make relevant preparations to permit application of the most efficient CBAM rates. Affected companies should act quickly to assess supply chain exposure and establish robust compliance processes as the CBAM regulatory landscape evolves.

Our CBAM team will provide further CBAM analysis and legal updates moving through this first year of the CBAM Definitive Phase - for further information, please contact the authors.