Importing 1,000 Tonnes? Freeze €250,000!

The hidden cash-flow trap of CBAM

Imagine receiving a letter from the authorities telling you that, before the end of the quarter, your company must temporarily set aside a cool quarter of a million euros. Not because you missed a tax payment or did something wrong — simply because the law assumes your imported products emit far more CO₂ than they actually do.

Sounds unrealistic? Unfortunately, it isn’t.

From 9 July to 6 August 2026, the European Commission is consulting stakeholders on a draft Delegated Regulation governing the sale and repurchase of CBAM certificates. EURANIMI is seizing this opportunity to highlight what we believe is one of the most significant — and least understood — liquidity challenges posed by the CBAM Regulation.

The devil is in the details…

Most importers know that from 2027 onwards, they will gradually have to purchase CBAM certificates. What is much less known is how Article 22(2) of the CBAM Regulation functions during the early years of the definitive system. At the end of every quarter, authorised CBAM declarants must hold certificates covering 50% of their year-to-date embedded emissions.

This sounds straightforward — until you consider the details.

Given the enormous number of installations that will have to be verified worldwide, independently verified emissions will simply not be available for many importers during the first years of the definitive CBAM system. Even so, importers are not allowed to estimate their suppliers’ actual emissions. Nor may they rely on figures provided by the producer.

Article 22(2) compels them to use mandatory default values — the only emissions figures legally recognised until verified data becomes available. These default values are not intended to reflect reality. They are deliberately set significantly higher than emissions from most installations to encourage producers to secure verified data quickly.

The policy goal may be understandable. The cash-flow consequences for importing SMEs, however, are a very different story.

A single shipment… €250,000!

Consider a simple example.

An SME imports 1,000 tonnes of stainless steel from a low-emitting producer with emissions of 1.5 tonnes of CO₂ per tonne. However, without verified data, the importer must use the mandatory default value of 8 tonnes of CO₂ per tonne.

Instead of calculating obligations based on 1,500 tonnes of CO₂, the importer must calculate on 8,000 tonnes. Article 22(2) then requires holding certificates covering 50% of those emissions.

In practice, this means purchasing about 3,250 extra CBAM certificates that wouldn’t be needed if verified emissions were available. At €76 per certificate, nearly €250,000 of working capital is temporarily frozen.

And herein lies the real problem.

Not one shipment… every shipment

Above example is for a single 1,000-tonne shipment. For many steel and stainless steel distributors, this is a fraction of annual imports. This mechanism applies repeatedly, every shipment imported before verified emissions data is available.

This isn’t a one-time liquidity challenge — it is a recurring issue that can immobilise substantial working capital for up to 13 months, even if actual emissions prove much lower.

Can importers at least recover their money?

Yes, eventually.

The Commission’s draft Delegated Regulation allows importers to sell back certificates if later verified emissions show they overpaid. This is a step forward.

However, under the proposed Regulation, this repurchase would normally be possible only once a year.

Not when needed. Not once a month. Not even every quarter. ONCE A YEAR!

This limitation is meant to prevent the CBAM certificate market from becoming a speculation tool, avoiding free options to buy low and sell high.

While preventing speculation is valid, should importing SMEs bear the financial burden caused by this system?

There’s a better solution

EURANIMI believes the issue must be addressed at the source: Article 22(2). In the initial years, the quarterly holding obligation should reflect actual emissions, even if not yet verified.

Until legislation changes, implementing rules should minimize the unnecessary financial strain caused by the current approach.

In this spirit, EURANIMI has submitted detailed feedback during the European Commission’s consultation on the draft Delegated Regulation covering CBAM certificate sales and repurchases.

Importers do not object to paying for the carbon embedded in their imports. But they should not finance, for over a year, certificates based on inflated default values that may never be needed.

Download EURANIMI’s full response to the EC’s public consultation to learn more.

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