How to Calculate Your CBAM Certificate Surrender Obligation

Every EU importer of CBAM-covered goods must surrender CBAM certificates by 30 September each year. This step-by-step guide explains exactly how to calculate the number of certificates you must surrender, how to account for the SA carbon tax credit, and how to avoid the EUR 100/tCO₂ non-compliance penalty.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

Overview

Every EU importer of CBAM-covered goods must surrender CBAM certificates by 30 September each year. The number of certificates equals the total embedded CO₂e emissions in your imports, minus any deductions for carbon prices already paid at origin.

This guide walks through the full calculation in six steps, using a real-world example: a South African steel exporter shipping 10,000 tonnes to an EU customer.

Step 1: Confirm Your Goods Are CBAM-Covered

CBAM applies to specific CN codes within six sectors: steel and iron, aluminium, cement, fertilisers, hydrogen, and electricity. Before calculating, confirm your product's CN code is on the CBAM-covered list.

Use the CN Code Lookup to search by product name or CN code. If your product is not listed, no CBAM obligation applies.

Example: CN code 7208.51 (flat-rolled steel, ≥4.75mm thick) — covered under CBAM steel sector.

Step 2: Determine Your Embedded Emission Factor

You have two options:

| Option | Method | When to Use | |--------|--------|-------------| | EU Default | Use the European Commission's published default value for your sector | When you do not have verified supplier emission data | | Actual Emissions | Use verified emission data from your supplier's MRV system | When actual data is lower than the default (reduces your obligation) |

EU Default Emission Factors (April 2026):

| Sector | EU Default (tCO₂/tonne) | |--------|---------------------------| | Steel (flat-rolled) | 2.18 | | Aluminium (primary) | 6.72 | | Cement (clinker) | 0.83 | | Fertilisers (ammonia) | 2.43 | | Hydrogen | 10.50 |

Example: Using EU default for steel: 2.18 tCO₂/tonne.

Step 3: Calculate Total Embedded Emissions

Multiply your export volume by the emission factor:

Total Embedded Emissions = Export Tonnes × Emission Factor

Example: 10,000 tonnes × 2.18 tCO₂/tonne = 21,800 tCO₂

Step 4: Calculate Gross CBAM Liability

Multiply total embedded emissions by the current EU ETS price. As of April 2026, the EU ETS price is approximately EUR ${ETS_PRICE_EUR}/tCO₂.

Gross CBAM Liability (EUR) = Total Embedded Emissions × EU ETS Price

Example: 21,800 tCO₂ × EUR 65.42 = EUR 1,426,156

Step 5: Deduct the SA Carbon Tax Credit

Under Article 9 of EU Regulation 2023/956, you can deduct the carbon price effectively paid in the country of production. For South Africa, this is the carbon tax rate.

SA Carbon Tax Rate (April 2026): R${SA_CARBON_TAX_ZAR}/tCO₂ ≈ EUR 11.80/tCO₂ (at R20/EUR exchange rate)

SA Tax Credit (EUR) = Total Embedded Emissions × SA Carbon Tax (EUR/tCO₂)

Example: 21,800 × EUR 11.80 = EUR 257,240

Step 6: Calculate Net CBAM Liability and Certificates Required

Net CBAM Liability = Gross CBAM Liability − SA Tax Credit

Certificates Required = Net CBAM Liability ÷ EU ETS Price

Example:

▸Net liability: EUR 1,426,156 − EUR 257,240 = EUR 1,168,916
▸Certificates: EUR 1,168,916 ÷ EUR 65.42 = 17,870 certificates

Each certificate covers one tonne of CO₂e. You must surrender 17,870 CBAM certificates by 30 September of the following year.

The Non-Compliance Penalty

If you fail to surrender the required certificates, the penalty is EUR 100 per tonne of uncovered emissions (Article 26, EU Regulation 2023/956). This penalty is not capped and accrues per shipment.

Example penalty for full non-compliance: 21,800 tCO₂ × EUR 100 = EUR 2,180,000

The penalty is 1.87× the compliance cost in this example — making non-compliance significantly more expensive than compliance.

Using the CBAM Calculator

The CBAM Liability Calculator performs all six steps automatically. Enter your sector, export volume, and optionally your actual emission factor to get an instant estimate of your gross liability, SA tax credit, net liability, and certificate count.

Key Dates

| Date | Event | |------|-------| | 31 January 2027 | CBAM annual declaration due (covering Jan–Dec 2026 imports) | | 30 September 2027 | First CBAM certificate surrender deadline | | 31 January 2028 | CBAM annual declaration due (covering Jan–Dec 2027 imports) | | 30 September 2028 | Second CBAM certificate surrender deadline |

Summary: The Six-Step Formula

▸Confirm your CN code is CBAM-covered
▸Choose EU default or actual emission factor
▸Calculate total embedded emissions (tonnes × EF)
▸Calculate gross CBAM liability (emissions × ETS price)
▸Deduct SA carbon tax credit (emissions × SA tax in EUR)
▸Calculate net liability and divide by ETS price for certificate count

For a complete compliance registration pathway, visit the Digital Product Passport Registry.

Frequently Asked Questions

When must CBAM certificates be surrendered?

CBAM certificates must be surrendered by 30 September each year, covering all embedded emissions in CBAM-covered goods imported into the EU during the previous calendar year. The first full surrender deadline is 30 September 2027, covering imports from January 2026.

How many CBAM certificates do I need to surrender?

The number of certificates equals the total embedded emissions (in tonnes of CO₂e) in your CBAM-covered imports for the year, minus any deductions for carbon prices already paid in the country of production (such as South Africa's carbon tax). Each certificate covers one tonne of CO₂e.

What is the EU default emission factor and when can I use it?

The EU default emission factor is a conservative (high) emission intensity value published by the European Commission for each CBAM sector. You may use it if you do not have verified actual emission data from your supplier. Using actual data (if lower than the default) reduces your certificate obligation.

Can I deduct South Africa's carbon tax from my CBAM obligation?

Yes. Under Article 9 of EU Regulation 2023/956, you can deduct the carbon price effectively paid in the country of origin. For South Africa, this is the carbon tax rate (R236/tCO₂ as of April 2026, approximately EUR 11.80/tCO₂). The deduction reduces the number of certificates you must surrender.

What is the penalty for failing to surrender CBAM certificates?

The penalty is EUR 100 per tonne of embedded emissions not covered by surrendered certificates (Article 26, EU Regulation 2023/956). This penalty is not capped and accrues per shipment. Repeated non-compliance can result in goods being blocked at EU customs.

What is the difference between gross CBAM liability and net CBAM liability?

Gross CBAM liability is the total embedded emissions multiplied by the EU ETS price. Net CBAM liability is the gross amount minus the deduction for carbon prices already paid in the country of production. Net CBAM liability is the actual amount you must pay in certificates.

Gate 3 — Complete Registration

✓ Gate 1 KYC · ✓ Gate 2 CBAM · Gate 3 DPP →

Digital Product Passport Registry

Complete all three compliance gates — Gate 1 KYC identity verification, Gate 2 CBAM financial authorisation, and Gate 3 Digital Product Passport registration — in one place at the DPP Registry.

Start Three Gates Registration →