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CBAM vs EU ETS: how they relate, how they differ, and why the price is linked

The CBAM is designed as the import-side mirror of the EU Emissions Trading System (EU ETS). It ensures that imported goods bear a carbon cost equivalent to what EU producers pay under the ETS. The CBAM certificate price is directly linked to the EU ETS auction price (Art. 21). As free allocation to EU producers is phased out under Art. 31, the CBAM rate increases proportionally. CBAMCheck includes an interactive dashboard projecting the phase-out schedule and your CBAM cost trajectory from 2026 to 2032.

Generate your CBAM dossier — €299Free check: does CBAM affect 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 link CBAM and EU ETS

Art. 21
CBAM certificate price = weekly average EU ETS auction price — direct linkage
Art. 31
Free allocation phase-out: 2.5% in 2026, increasing annually to 100% by 2034
2026–2034
Transition period where CBAM rate rises as free allocation falls — 8-year cost escalation

The CBAM–EU ETS phase-out timeline

1
2026: CBAM rate 2.5% — free allocation 97.5%
Art. 31: only 2.5% of embedded emissions require CBAM certificates. EU producers still receive 97.5% free allocation.
2
2027: CBAM rate increases — free allocation decreases
The phase-out accelerates. Each year, more emissions require CBAM certificates as EU producers lose free allocation.
3
2028–2030: mid-transition escalation
CBAM costs grow materially. Importers must plan for increasing certificate purchases year on year.
4
2031–2033: steep phase-out
Free allocation drops sharply. CBAM certificates cover the majority of embedded emissions. Cost impact becomes significant.
5
2034: full CBAM — zero free allocation
Art. 31 phase-out complete. 100% of embedded emissions require CBAM certificates. Full carbon cost parity between EU producers and importers.
6
CBAMCheck dashboard: 2026–2032 projection
The interactive HTML dashboard projects your CBAM cost trajectory based on the phase-out schedule, your import volumes and default or actual emissions values.

Three mistakes people make about CBAM and EU ETS

MISTAKE 1 — THINKING CBAM REPLACES THE EU ETS

Confusing the two systems

CBAM does not replace the EU ETS. The EU ETS applies to EU producers. CBAM applies to importers. They operate in parallel. CBAM ensures imports face the same carbon cost that EU production bears under the ETS.

MISTAKE 2 — IGNORING THE PHASE-OUT TRAJECTORY

Planning for 2026 costs without projecting to 2034

The 2026 CBAM rate is only 2.5%. By 2034 it reaches 100%. Companies planning only for 2026 costs will be surprised by the escalation. The CBAMCheck dashboard projects the full trajectory.

MISTAKE 3 — NOT UNDERSTANDING ART. 9 DEDUCTIONS

Overlooking carbon prices paid in the country of origin

Art. 9 allows deduction of carbon prices effectively paid in the country of origin (e.g. UK ETS, Korea ETS). Not claiming this deduction means overpaying for CBAM certificates.

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)).

Projecting CBAM cost trajectories for multiple importing companies?

The Professional Pack covers 70 dossier generations. Each dossier includes a 2026–2032 dashboard reflecting the phase-out schedule for that company's specific imports.

Request Professional Pack →
70 generations · 1 key · Phase-out projections for every 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.
How is the CBAM certificate price determined?
Art. 21: the CBAM certificate price equals the average closing price of EU ETS allowances on the common auction platform during each calendar week. It is a direct, weekly-updated linkage to the ETS market price.
What is the free allocation phase-out under Art. 31?
Art. 31 phases out free allocation to EU producers in CBAM sectors from 2026 to 2034. In 2026, only 2.5% of embedded emissions require CBAM certificates. This percentage increases each year until reaching 100% in 2034, at which point free allocation is zero.
Can I deduct carbon prices paid in the country of origin?
Yes. Art. 9(1) allows a reduction in the number of CBAM certificates for any carbon price effectively paid in the country of origin. Documentation must be certified by an independent person (Art. 9(2)). Countries with an ETS or carbon tax (UK, Korea, etc.) may qualify.
⚠️ 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.

CBAM starts at 2.5% in 2026 and reaches 100% by 2034. Know your trajectory now.

12 deliverables. 2026–2032 interactive dashboard. Phase-out projection. Art. 9 deduction analysis. €299.

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