If a carbon price was genuinely paid in the country of origin, Article 9 lets you deduct it — but the mechanics are more specific than "subtract what you paid."
Last verified: 02 September 2026
If a carbon price was genuinely paid on a good in its country of origin, Article 9 of EU Regulation 2023/956 lets you deduct that from your CBAM certificate obligation — the logic being you shouldn't pay twice for the same tonne of emissions.
The deduction is a fraction of the good's gross embedded emissions, scaled by how much of the CBAM certificate price was already covered by the price paid at origin:
The divisor is the CBAM certificate reference price for the relevant period — not the live/spot EU ETS auction price on any given day. This distinction matters: using the wrong divisor changes the fraction, and therefore the deduction.
Take a good with 500 tCO₂e of gross embedded emissions, where a genuine carbon price of €18.50/tCO₂e was paid at origin. Using the real Q2 2026 CBAM certificate reference price of €75.28/tCO₂e:
| Step | Calculation | Result |
|---|---|---|
| Price ratio | €18.50 ÷ €75.28 | 0.2457 (24.57%) |
| Capped at 100%? | min(1, 0.2457) | No cap needed — 0.2457 |
| Article 9 credit | 500 tCO₂e × 0.2457 | 122.87 tCO₂e deducted |
| Remaining obligation (before any benchmark credit) | 500 − 122.87 | 377.13 tCO₂e |
If this good also has an EU ETS free-allocation benchmark, that credit is calculated separately against the same 500 tCO₂e gross figure — not against the 377.13 tCO₂e left after the Article 9 deduction. The two credits are then combined and checked against the per-good floor below.
Per CBAM Q&A Q4.32, the combined benchmark credit and Article 9 credit on any single good can never exceed that good's own gross embedded emissions. If adding both credits together would push past 100% of the good's emissions, both are scaled down proportionally until they fit — a large Article 9 credit on one shipment can't offset a good with no credit at all elsewhere in the same declaration.
No — this is a common misreading. Per the draft implementing act on carbon-price deductions, the divisor is the CBAM certificate reference price for the relevant period (the same quarterly-then-weekly published figure used to cost certificates), not the live/spot EU ETS auction price on any given day.