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CBAM certificate buyback: Art. 23, the October deadline and the repurchase limit

If you purchased more CBAM certificates than needed, Art. 23 of Reg. (EU) 2023/956 allows you to request a buyback of the excess. The buyback must be requested before 31 October of the year in which certificates were surrendered. The repurchase price equals the price you originally paid. But there is a limit: the total number of certificates you can buy back cannot exceed the total you were obliged to purchase under the quarterly obligation (Art. 23(2)). CBAMCheck's certificate estimation helps you avoid overbuying in the first place.

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€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The certificate buyback numbers

Art. 23
Right to request buyback of excess CBAM certificates
31 October
Deadline to request buyback — of the year in which certificates were surrendered
Art. 23(2)
Buyback limit: cannot exceed the total quarterly certificate purchase obligation

How the certificate buyback process works

1
Purchase CBAM certificates throughout the year
Art. 20–22: you buy certificates quarterly to meet the 50% balance requirement (Art. 22(2)). If your estimates are conservative, you may end up with excess.
2
Submit your annual declaration by 30 September
Art. 6: the declaration confirms your verified total embedded emissions and the exact number of certificates to surrender.
3
Identify excess certificates
Compare certificates held vs certificates surrendered. The difference is your excess — certificates purchased but not needed.
4
Request buyback before 31 October
Art. 23(1): submit a buyback request through the CBAM Registry before 31 October. The Registry repurchases the excess at the price you originally paid.
5
Understand the Art. 23(2) buyback limit
The total certificates you can buy back cannot exceed one-third of the total certificates you purchased during the year. This prevents speculative overbuying.
6
Use CBAMCheck to estimate accurately and avoid excess
The best buyback strategy is not needing one. CBAMCheck calculates your certificate needs based on actual emissions data, reducing the risk of overbuying.

Three mistakes importers make with certificate buyback

MISTAKE 1 — MISSING THE 31 OCTOBER DEADLINE

Not requesting buyback in time

The buyback window closes on 31 October. After this date, excess certificates cannot be repurchased. Mark the deadline in your compliance calendar.

MISTAKE 2 — NOT KNOWING THE BUYBACK LIMIT

Assuming all excess certificates can be returned

Art. 23(2) caps the buyback at one-third of the total certificates purchased during the year. If you bought 300 certificates and needed 200, you can buy back up to 100 (one-third of 300) — which happens to cover the excess. But if you massively overbought, the cap may bite.

MISTAKE 3 — OVERBUYING DELIBERATELY AS A HEDGE

Purchasing significantly more certificates than estimated as a safety margin

While conservative estimates are prudent, massive overbuying ties up capital. CBAMCheck's estimation reduces uncertainty, and the quarterly purchase structure (Art. 22(2)) allows you to adjust throughout the year.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company's actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emissions calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionPlatform-locked
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML dashboard (2026–2032 projection)
  • 13,566 official default values integrated
  • English supplier letter template
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs brokers
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal ASKS for data. CBAMCheck CALCULATES it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete your declaration in the CBAM Registry.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS rate
EU ETS rate per certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased per Art. 16(4). The penalty applies per certificate not surrendered. Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): anyone introducing goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. Also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Managing certificate buyback for multiple importing clients?

The Professional Pack covers 70 dossier generations. Each includes accurate certificate estimation — reducing excess and buyback needs across your client portfolio.

Request Professional Pack →
70 generations · 1 key · Precise certificate estimation per client

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours forever.
Can I request a refund?
By activating the licence you give express consent for the immediate generation of digital content under Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical faults.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
Can I get a refund for excess CBAM certificates?
Yes. Art. 23(1) allows you to request a buyback of excess certificates before 31 October of the year in which they were surrendered. The repurchase price equals the price you originally paid.
What is the buyback limit under Art. 23(2)?
Art. 23(2) limits the total certificates you can buy back to one-third of the total certificates you purchased during the year. This prevents speculative overbuying and ensures the buyback right is used for genuine excess only.
How does CBAMCheck help avoid excess certificates?
CBAMCheck calculates your certificate needs based on your actual import data and emissions values (default or actual). More accurate estimation = less overbuying = less need for buyback.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

Excess certificates = tied-up capital. Accurate estimation avoids it. CBAMCheck calculates the right number.

12 deliverables. Certificate estimation based on 13,566 default values. Quarterly projections. Compliance calendar with buyback deadline. €299.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299