Who Pays for CBAM? Following the Money Across Global Supply Chains

The authorised CBAM declarant is the central statutory actor for import, declaration and certificate obligations.

Evidence

S-001, S-002 · Articles 4–6

Limitation

Representation and threshold cases must be checked against the exact consolidated provisions.

Prohibited inference

The authorised declarant necessarily bears the final economic cost.

An indirect customs representative can act as authorised CBAM declarant and then carries the Regulation's importer obligations for the represented goods.

Evidence

S-001, S-002 · Article 5(1a), (2) and (2a)

Limitation

The result depends on establishment, appointment, agreement and the represented import flow.

Prohibited inference

Every customs representative is automatically the CBAM payer.

Delegating submission of the declaration does not remove the authorised declarant's responsibility under the Regulation.

Evidence

S-001, S-002 · Article 5(7a)

Limitation

This is a statutory responsibility boundary, not advice on private recourse.

Prohibited inference

Commercial contracts cannot allocate operational work or financial risk.

The first definitive-period declaration is due by 30 September 2027 for calendar year 2026.

Evidence

S-001, S-002 · Article 6(1)

Limitation

This states the consolidated text checked at the research cut-off and must be rechecked before later reuse.

Prohibited inference

All certificate cash leaves the business only on the declaration deadline.

The declared certificate total is calculated after the permitted carbon-price reduction and the free-allocation adjustment.

Evidence

S-001 · Article 6(2)(c)

Limitation

Each adjustment has its own eligibility, evidence and calculation rules.

Prohibited inference

A foreign charge or supplier statement automatically reduces surrender.

For non-electricity goods, embedded emissions may be determined using actual emissions or applicable default values under the Regulation's methods.

Evidence

S-001 · Article 7(2) and Annex IV

Limitation

Method availability and requirements differ by good and implementing rules.

Prohibited inference

A declarant may freely select whichever value produces the lowest cost.

Actual-emissions declarations require verification by an appropriately accredited verifier under the definitive rules.

Evidence

S-001 · Article 8(1)

Limitation

Accreditation scope, timing and verification requirements remain controlling.

Prohibited inference

Any consultant or supplier assurance is sufficient verification.

A carbon-price reduction based on actual emissions requires an effectively paid third-country carbon price, net of rebates or compensation.

Evidence

S-001 · Article 9(1)–(3)

Limitation

Documentation, certification, payment and retention conditions apply.

Prohibited inference

Any carbon tax, climate policy or nominal allowance price is deductible.

Where default emissions are used, a carbon-price reduction is possible only through an applicable yearly default carbon price determined and published by the Commission.

Evidence

S-001, S-017 · Article 9(4)–(5); Commission legislation index checked 2026-08-10

Limitation

No applicable published default price or adopted Article 9(5) implementing act was identified at the research cut-off.

Prohibited inference

A declarant can presently rely on a default foreign-carbon-price deduction without an applicable published value and method.

A registered third-country operator may calculate installation emissions, ensure accredited verification, prepare carbon-price information and disclose it to an authorised declarant.

Evidence

S-001 · Articles 8(1) and 10(5)–(7)

Limitation

Registration and disclosure are voluntary; disclosure supports the declarant but does not make the operator the verifier or transfer the declarant's obligation.

Prohibited inference

The producer verifies its own data, must disclose under Article 10, or becomes liable for certificate surrender.

Certificate sales begin from 1 February 2027 through the common central platform to authorised declarants.

Evidence

S-001, S-002 · Article 20(1)

Limitation

Platform procedures and fees must be read with applicable delegated measures.

Prohibited inference

A 2026 import necessarily requires a certificate purchase during 2026.

The general certificate price uses weekly EU ETS auction closing-price averages, while 2026 embedded emissions use the relevant quarterly-average rule.

Evidence

S-001, S-002 · Article 21(1) and (1a)

Limitation

This is the statutory price mechanism, not a future price forecast.

Prohibited inference

A spot EUA quote is the definitive certificate cost for every import.

The first surrender occurs by 30 September 2027 for 2026 emissions, and the authorised declarant must have the required certificates in its Registry account.

Evidence

S-001, S-002 · Article 22(1)

Limitation

The amount still depends on verified/default emissions and statutory adjustments.

Prohibited inference

Surrender timing alone identifies annual accounting expense or working-capital need.

From 2027, a quarterly account-balance requirement references at least 50% of embedded emissions under the permitted calculation routes.

Evidence

S-001, S-002 · Article 22(2) and (2a)

Limitation

The rule includes specified methods, prior-year conditions and threshold timing.

Prohibited inference

Every importer must continuously pre-fund 50% from the first day of 2026.

Repurchase is request-based, time-limited and quantity-limited, with the repurchase price tied to the original purchase price.

Evidence

S-001, S-002 · Article 23

Limitation

Special 2026/2027 timing and threshold cases apply.

Prohibited inference

Excess certificates are always liquid or can be sold freely at the current market price.

Older unused certificates can be cancelled without compensation under the statutory timetable.

Evidence

S-001, S-002 · Article 24

Limitation

The 2027 treatment for certificates bought for 2026 emissions has a specific rule.

Prohibited inference

Unused certificates remain a perpetual transferable asset.

The OECD supply-chain model's main analysis assumes 100% cost pass-through across sectors.

Evidence

S-003 · PDF pp. 30 and 33–34

Limitation

The paper states sector and time variation can make pass-through lower.

Prohibited inference

Observed CBAM pass-through is 100% for every firm and product.

The OECD's Box 3 summarises mixed-method estimates of EU ETS cost pass-through, including ex-ante simulations and ex-post econometric studies, with wide ranges across sectors and studies.

Evidence

S-003 · Box 3, PDF pp. 33–34; endnotes 39–40, PDF p. 55

Limitation

These are literature estimates with different methods, periods and products, not observed CBAM outcomes.

Prohibited inference

The full range is historical empirical evidence or can be assigned to a company or CBAM transaction.

The OECD paper cites a Belgian-firm estimate of roughly 60% average short-term cost pass-through and uses 60% as a sensitivity case.

Evidence

S-003 · PDF pp. 34 and 48

Limitation

The estimate is not CBAM-specific and the sensitivity applies one average uniformly across sectors.

Prohibited inference

Sixty percent is the correct base case for all CBAM supply chains.

Under the OECD combined-policy Full Policy Mix, changing pass-through from 100% to 60% changes modelled EU value-added results materially.

Evidence

S-003 · Table 6, PDF p. 49

Limitation

The table combines ETS-price, free-allocation and CBAM policies in a static 2019-based experiment.

Prohibited inference

The difference measures how much cost consumers or importers will bear in 2026.

The OECD mechanism permits part of an import price increase to be absorbed by an exporter when an importer has sufficient market power to negotiate lower exporter margins or prices.

Evidence

S-003 · Footnote 41, PDF p. 55

Limitation

This is a conditional model/economic mechanism rather than an observed allocation.

Prohibited inference

Non-EU exporters will absorb the CBAM cost.

The OECD model propagates covered-input price changes into downstream sectors through direct and indirect value-chain channels.

Evidence

S-003 · PDF pp. 35 and 42–44

Limitation

The magnitude depends on the model's pass-through, substitution, elasticity and baseline assumptions.

Prohibited inference

Every downstream firm can or will pass the full change to customers.

In the OECD setup, higher origin emissions intensity and absent carbon pricing worsen the relative price and competitiveness channel compared with cleaner or carbon-priced sources.

Evidence

S-003 · PDF p. 35

Limitation

This is modelled direction under the paper's country-sector averages and policy assumptions.

Prohibited inference

A country ranking determines a supplier's installation-level commercial outcome.

Where applicable, certificate surrender is reduced through the operative free-allocation adjustment; the adjustment for electrical energy is zero.

Evidence

S-001, S-005, S-012 · Regulation Article 31; Directive Article 10a(1a); Implementing Regulation (EU) 2025/2620 Articles 1–4

Limitation

The CBAM factor is not a simple percentage of 'full CBAM payable'; use the canonical guide for the operative formula and schedule.

Prohibited inference

Every covered good receives an adjustment, or a fully implemented model scenario is a 2026 company cost estimate.

A defensible company analysis needs low, base and high cases for emissions, eligible carbon-price reduction, certificate price, pass-through, supplier response, customer response and volume.

Evidence

S-001, S-003 · Regulation Articles 6–10 and 20–24; OECD PDF pp. 33–35 and 48–49

Limitation

Scenario ranges are decision support and must be populated with company evidence.

Prohibited inference

A scenario is a legal conclusion, quote, budget guarantee or forecast.

No universal final payer or pass-through percentage is claimed for CBAM.

Evidence

S-001, S-003, S-007 · Legal actor rules; OECD assumptions and limitations; exposure-method limitations

Limitation

Observed definitive-period evidence is not yet sufficient to identify one final-incidence rule.

Prohibited inference

Importer, exporter, downstream buyer or consumer always bears the burden.

Where the importer is not established in a Member State, the indirect customs representative must obtain authorised-CBAM-declarant status.

Evidence

S-001, S-002 · Article 5(2)

Limitation

The mass-threshold exemption can remove substantive obligations while customs identity and monitoring remain relevant.

Prohibited inference

The non-EU seller, buyer or customs intermediary necessarily absorbs the commercial cost.

Once the single mass-based threshold is exceeded during a year, the Regulation applies to embedded emissions in all covered goods imported by that importer during that calendar year.

Evidence

S-001, S-002 · Article 2a(1)–(4)

Limitation

The rule is per importer; electricity and hydrogen are excluded from the mass-based exemption. Use the threshold guide for full scope detail.

Prohibited inference

Only shipments after the crossing point create exposure, or group-wide tonnage can be used without checking customs identities.

The authorised declarant is the statutory certificate purchaser, and the Regulation permits common-platform costs to be financed by fees payable by authorised declarants.

Evidence

S-001 · Article 20(1), (4), (5) and (5a)

Limitation

No fee amount is estimated in this report; detailed fee operation depends on applicable measures.

Prohibited inference

A published or universal platform-fee amount is already available, or the declarant must economically absorb it.

An operator's registration and disclosure route is voluntary language: an operator may register and may disclose verified emissions and carbon-price information.

Evidence

S-001 · Article 10(1), (5) and (7)

Limitation

Commercial arrangements can still require data delivery; the statutory operator route does not transfer declarant responsibility.

Prohibited inference

Every foreign supplier is legally required to register or disclose through Article 10.

The Article 9 default-carbon-price framework does not establish that a usable country default price or all detailed implementing mechanics were available at the research cut-off.

Evidence

S-001, S-017 · Article 9(4)–(5); Commission legislation index checked 2026-08-10

Limitation

Article 9 says the Commission may determine and publish yearly defaults from 2027; the relevant adopted implementing act was not identified on the official index at the cut-off.

Prohibited inference

A declarant can presently rely on a default foreign-carbon-price deduction without an applicable published value and method.

For 2026 imports, the certificate price is tied to the quarter of import, while external certificate sales begin on 1 February 2027 and first surrender falls on 30 September 2027.

Evidence

S-001, S-002, S-011 · Articles 20(1), 21(1a), 22(1) and 36(2)(d)

Limitation

This separates statutory price attribution from cash purchase; it does not set supplier, broker or customer settlement dates.

Prohibited inference

The EU collects certificate cash at import clearance during 2026.

Certain newly established authorisation applicants must provide a guarantee, but that collateral requirement is not a CBAM certificate purchase.

Evidence

S-001, S-008, S-009 · Article 17(5); authorised-declarant implementing procedures

Limitation

Applicant facts and competent-authority decisions determine the exact requirement.

Prohibited inference

The authorisation guarantee is the CBAM charge or final certificate liability.

COM(2026) 616 remains a Commission proposal and does not replace the adopted phase-in schedule at the research cut-off.

Evidence

S-005, S-019 · Directive Article 10a(1a); COM(2026) 616 title and status

Limitation

Recheck only after final adoption and Official Journal publication.

Prohibited inference

A proposed phase-in amendment or downstream extension is current law.