What is CBAM exposure?
From 1 January 2026, the EU CBAM enters its definitive phase: importers of CBAM goods must ultimately declare embedded emissions and surrender CBAM certificates corresponding to those emissions (after applicable reductions). The CBAM Exposure Calculator is designed to help you estimate potential CBAM-related costs based on your historical import activity and user-defined assumptions.
This calculator is an exposure tool (forward-looking cost approximation), not your legal CBAM declaration. It is intended for budgeting, scenario analysis, procurement discussions, and supplier outreach.
Why your exposure is currently based on defaults
In the definitive period, “actual-value” CBAM accounting requires both the product-level actual emissions intensities and the actual benchmarks reported by an installation.
Today, many users have actual emissions intensity from suppliers, but do not yet have the benchmark-alignment data needed to run a robust “actual mode” exposure calculation. Until that benchmark-alignment data is available, the calculator runs in Default Mode.
Default Values
When actual benchmark data is missing, we calculate exposure using:
EU default embedded emissions values (direct, and where applicable indirect), and
default CBAM benchmark / free-allocation adjustment inputs aligned to those defaults (for a given Country of Origin and production route)
This approach is consistent with the EU’s own logic that where default values are used for embedded emissions, the related free-allocation adjustment is also calculated based on default values.
Actual Values
Once suppliers provide the additional information required to align their reported emissions with the relevant benchmark/route logic, we will switch your exposure calculation to use:
supplier actual embedded emissions, and
the corresponding actual-data method for the free-allocation adjustment (as applicable).
Note: At this time, very few installations have reported their actual benchmarks. As a result, we are unable to provide accurate actual cost calculations consistently.
How the calculator works
Users can apply time filters to estimate potential CBAM exposure in 2026 based on import volumes from a selected historical period.
Outputs
Based on your CBAM Reports that you have prepared, the exposure module returns:
Estimated CBAM cost per tonne (€/t of product), and
Estimated total CBAM cost (€) over the selected volume.
Calculation methodology (exposure estimate)
Step 1 - Embedded emissions per tonne
We determine an embedded emissions intensity (tCO₂e per tonne of product):
In Default values: EU default values are used for that country of origin.
In Actual values: supplier actual values are used (once benchmark-alignment data is available).
Step 2 - Apply the benchmark / free-allocation adjustment
CBAM costs are reduced by an adjustment reflecting the EU ETS free allocation logic under CBAM (the “free allocation adjustment” under Article 31). CBAM benchmarks are designed to reflect EU ETS benchmarks and may be production-route specific for certain goods (e.g., crude steel routes; primary vs secondary aluminium).
Because many users do not yet have benchmark-alignment data from suppliers, we currently apply this component using default benchmark/adjustment inputs (Default Values). Once the required supplier benchmark-alignment data is available, this will be updated accordingly (Actual Values).
Step 3 - Multiply by the CBAM certificate price assumption
For 2026 exposure modelling we use a user-set EUA/CBAM price assumption (e.g., €90/tCO₂e).
EU published methodology note: for 2026, the price is calculated on the basis of four quarterly averages of EU ETS allowance prices, and from 2027 it moves to a weekly average.
Step 4 - Deduct carbon price paid overseas (if applicable)
If your supplier provides evidence/inputs for a carbon price already paid in the country of origin, we deduct it (converted using an average FX rate for the selected period).
Calculation overview
CBAM Cost (€/t) = ([Direct EF (tCO2/t) - (Benchmark (tCO2/t) × Phase In Rate)] * EUA Price (€/tCO2)) - Carbon price paid overseas (€/t)
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.
Formula for fertilizers, ammonia and cement products:
CBAM Cost (€/t) = ( CBAM Certificate Price (€/tCO2e) × [(Direct EF (tCO2e/t) + Indirect EF(tCO2e/t)) - (Benchmark (tCO2/t) × Phase In Rate)] ) - Carbon price paid overseas (€/t)
Key limitations (important)
This tool provides indicative estimates, not a verified CBAM liability.
If you have actual emissions intensity but no benchmark-alignment data, we will continue to show Default Mode exposure to avoid producing a “false precision” number.
CBAM is designed to be phased in gradually through to 2034, in parallel with the phase-out of EU ETS free allocation; year-on-year cost impacts will change over time.
What we need from suppliers to switch you to “Actual Mode”
To move from Default Mode to Actual Mode for exposure (and ultimately support declaration-grade workflows), you typically need supplier data that allows:
confirmation of the installation, product, and production route (where relevant), and
consistent mapping to the applicable benchmark/CBAM benchmark logic used for the Article 31 free-allocation adjustment.
Legislative references (for this article)
Regulation (EU) 2023/956 (CBAM Regulation) – establishes CBAM and the definitive-period obligation framework.
Commission Implementing Regulation (10.12.2025) on the calculation and publication of the price of CBAM certificates (quarterly averages in 2026; weekly from 2027).
Commission Implementing Regulation (05.12.2025) on the free allocation adjustment (Article 31) and the conditions for using actual vs default values in that adjustment.
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.
2026: 2.5%
2027: 5.0%
2028: 10.0%
2029: 22.5%
2030: 48.5%
2031: 61.0%
2032: 73.5%
2033: 86.0%
2034: 100.0%