Who pays CBAM? Three common ways buyers and suppliers split the cost
By law the EU importer pays for CBAM, but the cost lands in your price talks. Three common arrangements, what each means for your margin, and what to agree in writing.
Checked against the EU rules on 6 October 2026.
By law the cost sits with the EU importer. Its authorised CBAM declarant buys certificates for goods imported from 1 January 2026 and surrenders them with the annual declaration. As the exporter you have no obligation under EU law. But your buyer compares offers on price plus CBAM, so the cost shows up in your price talks.
For wire rod from India on EU default values, CBAM adds about €253 a tonne for 2026 imports at €75 per tonne of CO2, and more every year after. That is the amount being split.
Three common arrangements
1. Price excludes CBAM: the buyer pays
Your price stays as it is and the buyer pays for the certificates. Expect the buyer to compare you with suppliers whose verified figure is lower, and to ask for your data. This works best when your own figure is low and verified, because then the buyer's cost is low too.
2. Price includes an allowance: you pay
You add an estimate of the CBAM cost to your price, or give a discount of that size. You carry the risk that the certificate price or the mark-up on defaults rises. State the basis you used: the import year, the CO2 price, and whether you used the EU default or a verified figure.
3. Settle later: adjust after the declaration
You agree the price without CBAM and settle the actual certificate cost once it is known. Declarations for 2026 imports are due by 30 September 2027, so the settlement comes long after delivery. It needs a clear basis: tonnes, the emissions figure used, the official certificate price, and who sends which data by when.
A special case: you sell DDP
Under DDP you are the importer. A company that is not established in the EU has to use an indirect customs representative in the EU that holds authorised CBAM declarant status and takes on the CBAM obligations. The certificate cost is then yours, through that representative.
What to agree in writing
- Who buys the certificates, and whether your price includes them.
- The basis: EU default value or verified figure, which import year, and which certificate price (quarterly in 2026, weekly from 2027).
- Which data you send, in what format and by when. Your buyer needs it well before its 30 September deadline.
- Who pays for verification, and what happens to the price if a verified figure arrives later.
- How a change in the certificate price or the rules is handled.
This page explains common practice. It is not contract wording or legal advice: have your contract reviewed by a lawyer.
Tools that help
- The cost calculator gives a ready line for your quotation, CBAM included or not.
- The buyer summary sends your figures to the buyer in their language.
- The emissions calculator shows your own figure and whether verification pays.
Read next: default values or actual emissions.
General information for planning, not legal, tax or customs advice. See the disclaimer.