CBAM Regulatory Intelligence

CBAM regulation, explained with the calculation attached

Every guide here follows the same discipline: cite the primary EU regulation, show the arithmetic, then link to the live tool that applies it. No estimates presented as facts, no figures cited from memory.

Default SEE Values & the Art. 7(3) Markup

Commission default emissions values under EU IR 2025/2621 (corrected by IR 2026/1740), and the real escalating 10%/20%/30% markup schedule for using them instead of verified actual data.

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CBAM Certificates: Pricing, Cadence & Surrender

How the certificate price is set each quarter in 2026 (weekly from 2027), how many certificates you owe, and the Article 26 penalty for under-surrender.

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Free Allocation Phase-Down (CBAM Factor)

How the EU ETS free-allocation benchmark credit phases out from 97.5% in 2026 to 0% in 2034 — and the common mistake of applying it to the whole obligation instead of just the credit.

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Third-Party Verification Requirements

ISO 17029 accreditation, what a verifier actually checks, and the August 2026 verification guidance timeline.

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The 50-Tonne De Minimis Threshold

The threshold is a single annual aggregate across steel, aluminium, fertilisers, and cement combined (not per CN code) — plus the hydrogen/electricity exclusion and the anti-circumvention flag on split shipments.

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Article 9: Carbon Price Already Paid Deduction

How a carbon price paid in the country of origin reduces your CBAM certificate obligation — the parallel-credit formula, the correct reference-price divisor, and a worked example.

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Who Can File a CBAM Declaration, and When

The Authorised Declarant requirement (mandatory from 1 Jan 2026), the real 30 September deadline, and what a declaration needs to pass registry submission.

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EU CBAM vs UK CBAM — The Real Differences

UK CBAM is a separate regime, not a UK copy of EU CBAM — different mechanism, deadlines, and verification standard, side by side.

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CBAM 2028 Downstream Expansion — Proposed, Not Yet Law

The Commission's proposal to add ~180 downstream products from 1 Jan 2028 (COM(2025) 419) — where it actually stands in the legislative process right now.

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Monitoring Plan & Source-Stream Requirements

What actually produces a defensible SEE figure: source streams, methodology justification, and the conditional elements (PFC methodology, waste gas, zero-rated fuels) — verified against EU Reg 2023/956 Art. 8.

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CSCF — the Cross-Sectoral Correction Factor

Why the Cross-Sectoral Correction Factor is not optional in the benchmark-credit formula (currently 1.0, per Commission CBAM Guidance No. 4), and a real correction history from our own calculation engine.

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Aluminium PFC Emissions — the Anode Effect

How perfluorocarbon emissions from the anode effect are calculated, the CF4/C2F6 GWP constants, and why anode-effect control can roughly triple embedded emissions at identical production volume.

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