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CBAM Exposure Methodology Document

A quick guide to CBAM exposure calculations

Updated over a week ago

What is CBAM exposure?

From 1 January 2026, all importers will be required to declare the embedded emissions of their imports and purchase Carbon Border Adjustment Mechanism (CBAM) certificates as an allowance in response. The CBAM exposure calculator provides an approximation of the value of certificates that may be required based on historical import data. This tool estimates potential 2026 CBAM costs using past import data and market-driven carbon price projections.

Users can apply time filters to estimate potential costs in 2026 based on import data from a selected period.

Disclaimer: All cost calculations provided by this tool are approximate estimates based on available product benchmarks and projected EU Emissions Trading System (ETS) prices for 2026. These projections are subject to change and should not be considered definitive financial obligations.

Calculation Methodology

CBAM Cost (€/t) = EUA Price (€/tCO2e) × [Direct EF (tCO2e/t) - (Benchmark (tCO2e/t) × Phase In Rate)]

Total CBAM Cost (€) = Volume (tonnes) × CBAM Cost (€/t)

Individual Components:

The cost per tonne of an imported product is derived from the following components:

Direct emission factor (EF):

This represents the direct embedded emissions associated with a particular Combined Nomenclature (CN) code, as outlined in the summary communication sheet. If a specific CN code lacks data or relies on more than 20% default values, the EU-provided default values for embedded emission factors will be applied.

Please note, for the CBAM cost calculations for fertilizers, ammonia and cement products, both direct and indirect emission factors are used.

Updated formula for fertilizers, ammonia and cement products:

CBAM Cost (€/t) = EUA Price (€/tCO2e) × [(Direct EF (tCO2e/t) + Indirect EF(tCO2e/t)) - (Benchmark (tCO2/t) × Phase In Rate)]

CBAM Benchmarks

CBAM benchmarks represent a standardized emissions intensity value (in tCO₂ equivalent per tonne of product) that serves as a reference for determining the embedded emissions of an imported product. Currently the EU has not published any benchmark values specific to CBAM. As a proxy, we use the EU ETS benchmarks provided for phase 4 (2021-2030) of the ETS. Please note:

  • We have mapped the available benchmarks for EU ETS to CN codes under the scope of CBAM. Our mapping is available here (Refer to tab: All CN codes).

  • Certain CN codes do not have a direct benchmark mapping. Therefore, exposure values cannot be calculated for these codes. A list of such CN codes is available here (Refer to tab: No benchmark CN codes).

  • Under EU CBAM, processed products will likely have higher benchmarks compared to the benchmarks set under the ETS. These product-level benchmarks are expected to be published by the EU in Q3 2025.

  • In scenarios where the intensity is below the benchmark value, there is zero cost obligation.

EUA price

The EUA (European Union Allowance) price used in these calculations represents an estimated carbon price for 2026. This value is based on multiple publicly available market reports, analyst commentaries, and future price projections. Please note, the estimated CBAM price for 2026 is speculative and subject to fluctuations in the carbon market. The actual price may vary. The assumed 2026 EUA price used for exposure calculations is €90/tCO₂e.

Phase-In rate

The CBAM Phase-In Rate is a percentage applied to reduce the impact of CBAM costs during the transition period (2026–2034). The phase in rate for 2026 is 97.5 %. This means that in 2026, only 97.5% of the calculated CBAM cost will be charged, and this percentage will decrease each year until 2034, when importers will bear 100% of the CBAM cost.

Carbon price paid overseas

The carbon price paid overseas refers to any carbon costs that an importer has already paid in the country of origin before bringing goods into the EU. Due to limited available data, this factor has currently been excluded from CBAM cost calculations. The exclusion of overseas carbon pricing from our calculations may result in variations from actual CBAM obligations.

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