How much relief does the 97.5% CBAM factor give in 2026? A calculator

Under CBAM (the EU's Carbon Border Adjustment Mechanism, its carbon charge on imports), 2026 relief is a fixed deduction per tonne of goods: 0.975 times an EU benchmark, subtracted from the emissions the importer declares. A benchmark records what an efficient EU plant emits making the same product by the same production route, blast furnace against electric arc, for example. Declare at the benchmark and the deduction removes 97.5 per cent of the bill. Declare above it, and every extra tonne of emissions pays the certificate price (the price importers pay per CBAM certificate, with one certificate surrendered per tonne of embedded emissions) in full. Our calculator down below runs that subtraction for any product line you give it.

How the 2026 free-allocation deduction is calculated

Commission Implementing Regulation (EU) 2025/2620 of 16 December 2025 sets the deduction at the CBAM factor of 97.5 per cent multiplied by the EU benchmark for the product's production route. The result is expressed in tonnes of carbon dioxide equivalent (tCO2e) per tonne of goods. Producers inside the EU Emissions Trading System (the ETS, the bloc's carbon market) still receive free allowances measured against those same benchmarks. Article 31 of the CBAM Regulation therefore requires the import charge on cement, iron and steel, aluminium, fertilizers and hydrogen to be reduced to match; electricity, which earns no free allocation inside the ETS, gets an adjustment of zero. Imports, in other words, get the same relief EU producers already receive through free allowances, sector by sector.

The deduction enters the calculation as a level: a fixed quantity of emissions, in the same units as the declared figure. Multiplying a benchmark by the factor produces another quantity of emissions: for hot-rolled flat steel made by the blast furnace and basic oxygen furnace route, the benchmark of 1.370 yields a deduction of 1.336 tonnes of carbon dioxide equivalent per tonne of steel. That fixed quantity is then subtracted from whatever the importer declares. The instrument removes one benchmark-sized quantity of emissions from every declaration, and each tonne declared above that quantity pays the full certificate price.

One ratio sets the relief share for every consignment: declared emissions divided by the benchmark, with relief meaning the share of the gross bill the deduction removes. Declared emissions at the benchmark receive relief of 97.5 per cent. Declared emissions at twice the benchmark receive 48.8 per cent, and the static table inside the exhibit continues the series at higher ratios.

Importers who cannot obtain verified emissions data from their supplier must declare using the default values in Implementing Regulation (EU) 2025/2621, as corrected by Implementing Regulation (EU) 2026/1740, one value per country and product. Each default also carries a mark-up that starts at 10 per cent in 2026 and rises to 30 per cent from 2028; fertilizer defaults are exempt from the mark-up and increase 1 per cent a year for inflation instead. As a result, an importer relying on defaults in 2026 declares more emissions than the published country-level figure before the subtraction even starts.

Default values describe country averages and are set conservatively above those averages, while the benchmark describes an efficient EU plant. Fastmarkets (a commodity price reporting agency) finds the defaults far above the relevant benchmarks for a number of countries and products. From that comparison, it puts the resulting average effective tariff on hot-rolled coil above 15 per cent for 2026.

I would pull one number first for every product line: the marked-up default value divided by the benchmark, one division per line. A budget built on the 2.5 per cent shorthand, gross embedded emissions multiplied by 2.5 per cent, should be rerun line by line. Supplier engagement for verified data should then be ranked by the same ratio, ahead of import volume, since the ratio sets how much of each line's bill is open to reduction.

The free Regulatory Readiness Assessment handles the prior question, whether CBAM applies to your imports at all, from a short set of intake questions.

Regulatory Readiness Assessment

CBAM Relief Deduction Calculator

Figure 1. Relief under the 2026 free-allocation deduction, computed as 0.975 × benchmark ÷ declared emissions intensity and floored at zero. At the hot-rolled coil benchmark of 1.370 tCO2e per tonne, relief falls from 97.5 per cent at the benchmark to 48.8 per cent at twice it and 16.3 per cent at six times it. Sources, preset derivations, and the correction-factor assumption sit in the methods note at the foot of the exhibit. Analysis: Gasilov Group, current as of August 2026.

What relief looks like at the published default values

At the published Q1 2026 certificate price of EUR 75.36, Fastmarkets' default-basis cost for Turkish hot-rolled coil comes to EUR 100.55 per tonne. That figure is possible because relief at Türkiye's marked-up default runs at 50 per cent, roughly half the relief the factor's headline suggests.

The arithmetic behind that figure is short enough to run on paper in one line. Türkiye's marked-up default for the blast furnace route implies 2.670 tonnes of embedded carbon dioxide per tonne of steel. The fixed deduction removes 1.336 of those tonnes, and the remaining 1.334 certificates per tonne carry the whole cost at the certificate price.

A different reading of the factor circulates in cost guides and commentary: take gross embedded emissions, multiply by 2.5 per cent, and call the product the 2026 bill. Put in euro terms, that is about EUR 5 per tonne on the same Turkish cargo (computed here from the same inputs), against the EUR 100.55 the deduction method produces. The shortcut applies the discount to the importer's own declared emissions. The instrument applies it to the EU benchmark, then subtracts, and the two calculations agree in one case: a declaration that equals the benchmark itself.

The certificate prices used in these figures are the two the Commission has published, EUR 75.36 for the first quarter and EUR 75.28 for the second, each applying to goods imported during its own quarter. Certificate purchases open on 1 February 2027, and the first annual declaration, covering all 2026 imports, falls due on 30 September 2027. Verified supplier data obtained before that date replaces the marked-up default for the whole 2026 year. An importer with a high-ratio product line accordingly saves more per euro spent obtaining verified data, wherever actual performance beats the marked-up default, than on any other compliance line item. Our post on who regulates AI's environmental footprint places CBAM among the EU's other border instruments.

Every output of the calculator moves with the certificate price, the one input with two published values so far. The deduction side of the calculation, 1.336 tonnes per tonne of blast-furnace steel, stays fixed until the benchmarks themselves are revised. The certificate price side moves on a schedule: the Commission's price table sets 5 October 2026 for the Q3 2026 price and 4 January 2027 for Q4, and from 2027 the price resets weekly.

If you already know what you need, or want help finding out, get in touch and we can scope it.

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Rafael Rzayev is partner for Trade, Customs & Sustainability Regulation at Gasilov Group, where he works on CBAM, EUDR (the EU Deforestation Regulation), the EU Forced Labor Regulation, and cross-border compliance. Meet our partners →

Frequently Asked Questions (FAQ)

Does the deduction change if I declare verified actual emissions?

Yes; Implementing Regulation (EU) 2025/2620 provides an actual free-allocation adjustment that follows the real production process and composition of the goods when actual emissions are declared. The same regulation created a separate benchmark for natural-gas direct reduced iron, a route whose ordinary hot-metal benchmark would have left it owing no certificates at all in the early years.

Who is exempt from CBAM entirely in 2026?

Importers whose CBAM-covered imports total 50 tonnes or less in a year are exempt under the de minimis threshold introduced by the 2025 Omnibus amendment, Regulation (EU) 2025/2083. The threshold is an annual aggregate across all CBAM sectors and products, and crossing it at any point in the year puts every tonne the importer brought in that calendar year in scope.