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How the CBAM free allocation adjustment works under Art. 31 — the phase-out schedule that escalates your certificate cost from 2.5% in 2026 to 100% by 2034

You need to understand the CBAM free allocation adjustment. Under Art. 31 of Reg. (EU) 2023/956, the number of CBAM certificates you must surrender is adjusted to reflect the free allocation of EU ETS allowances given to European producers of the same goods. While EU producers receive free allowances, importers get a proportional reduction in their CBAM certificate obligation. As free allocation phases out under the EU ETS, the CBAM certificate obligation increases. The schedule starts at 2.5% in 2026 and reaches 100% by 2034. CBAMCheck applies this adjustment automatically in every dossier and projects costs through 2032 in the interactive dashboard. 12 deliverables. €299.

Generate your CBAM dossier — €299Free check: does CBAM apply to you?

€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 numbers that matter for your CBAM compliance

2.5%
CBAM rate in 2026 — only 2.5% of embedded emissions require certificates
100%
By 2034 — full CBAM certificate obligation as free allocation ends
Dashboard
Interactive 7-year projection showing escalating costs

Your CBAM compliance timeline

1
Understand the principle
Art. 31: CBAM certificate obligations are reduced proportionally to the free allocation EU producers receive. As free allocation decreases, CBAM increases.
2
Know the phase-out schedule
2026: 2.5%. The percentage increases annually as the EU ETS free allocation phases out, reaching 100% by 2034 when no free allocation remains.
3
See the impact on your costs
In 2026, you pay certificates on only 2.5% of embedded emissions. By 2030, significantly more. By 2034, full exposure. The cost curve is steep.
4
Plan procurement strategy
The escalating CBAM cost may change your sourcing economics over time. Origins with lower emissions become progressively more competitive.
5
Apply the adjustment in your declaration
Art. 6(2)(c): certificates surrendered reflect the Art. 31 adjustment. CBAMCheck calculates this automatically.
6
Use the dashboard for long-term planning
CBAMCheck’s interactive HTML dashboard shows the cost projection through 2032, allowing management to plan for the escalation.

Three mistakes that inflate your CBAM cost or create compliance risk

MISTAKE 1 — IGNORING THE ADJUSTMENT

Calculating certificates without the Art. 31 free allocation deduction

In 2026, only 2.5% of embedded emissions require certificates. Ignoring this adjustment massively overestimates your 2026 cost.

MISTAKE 2 — IGNORING THE ESCALATION

Planning only for 2026 without seeing the 2027–2034 trajectory

2.5% in 2026 feels manageable. But the cost escalates each year. Long-term supply contracts must factor this in.

MISTAKE 3 — NO PROJECTION

Not providing management with a multi-year cost forecast

CBAMCheck’s dashboard shows the 7-year cost curve. Essential for procurement strategy and budget planning.

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.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements.

7

Verification Preparation

Structured preparation for Art. 8 verification. Annex VI checklist included.

8

Supplier Letter Template

Model letter requesting emissions data from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations, annual declaration deadline and key milestones.

10

Executive Summary

One-page CBAM exposure overview for management reporting.

11

Interactive HTML Dashboard

Standalone dashboard with 2026–2032 projections. Works offline.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines and 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 emission 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 projectionInside platform
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML Dashboard (projection 2026–2032)
  • 13,566 official values integrated
  • Template letter in English for supplier
  • 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 representatives
  • 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 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 the CBAM Registry submission.

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 excess emissions penalty
EU ETS rate per missing 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 pursuant to Art. 16(4). 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): a person who introduces goods without authorisation faces a penalty of 3 to 5 times the standard penalty. This also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Projecting CBAM costs across multiple origins and years?

Professional Pack: 70 generations. Each dossier includes the Art. 31 adjustment and the multi-year dashboard.

Request Professional Pack
One-business-day response · No sales call required

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

What is the CBAM rate in 2026?
2.5% of embedded emissions require certificates, reflecting the high level of free allocation EU producers still receive.
When does CBAM reach 100%?
By 2034, when the EU ETS free allocation for covered sectors is fully phased out. From that point, every tonne of embedded CO₂e requires a CBAM certificate.
Does CBAMCheck apply the adjustment automatically?
Yes. Every dossier applies the Art. 31 adjustment for the relevant year. The dashboard projects the cost through 2032.
How does this affect my sourcing decisions?
As the CBAM rate increases, the cost difference between high-emission and low-emission origins widens. By 2030–2034, the CBAM cost may be a decisive factor in supplier selection.
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours to keep.
Can I get a refund?
Upon activating the licence you give express consent for immediate generation of digital content pursuant to Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for a reproducible technical fault.
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.
⚠️ 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.

2.5% today. 100% by 2034. See the cost curve now.

12 deliverables. Art. 31 adjustment automatic. Interactive 7-year dashboard. €299.

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