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Requirement · FIN-08

Apply the Commission's conversion rules when turning a carbon price paid abroad into a reduction in CBAM certificates, including the evidence of actual payment and any deduction of Paris Agreement Article 6 carbon credits.

Authorised CBAM declarants claiming a carbon price paid in a third country must comply, and it sits in an act that is partly law and partly a proposal.

Why it matters

The act this comes from is partly law in force and partly a proposal that can still change.

  • It is Art. 1(7)(b)(1), replacing the first subparagraph of Art. 9(5) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
  • The act gives its timing as: from entry into force (third day after publication), Art. 2. as of 2026-08-14
  • It names 4 industries by name: Steel, Aluminium, Cement and Chemicals. as of 2026-08-14
  • Compliance is checked by accredited third party, annual. as of 2026-08-14
Addressee Authorised CBAM declarants claiming a carbon price paid in a third countryAct COM(2025) 989 final, 2025/0419 (COD)Article Art. 1(7)(b)(1), replacing the first subparagraph of Art. 9(5) of Regulation (EU) 2023/956Class Businesses

The rule

New — no predecessor
Trigger

claim for a reduction of CBAM certificates on account of a carbon price paid in a third country

Obligation

Apply the Commission's conversion rules when turning a carbon price paid abroad into a reduction in CBAM certificates, including the evidence of actual payment and any deduction of Paris Agreement Article 6 carbon credits.

Who is affected

Addressee
Authorised CBAM declarants claiming a carbon price paid in a third country
Class
Businesses
Sectors
Names Steel, Aluminium and metals, Cement and concrete, Chemicals and refining
Applies
from entry into force (third day after publication), Art. 2

Burden drivers

D1 · D2 — 2 of 7 marks fire on this provision.

Source text

Verbatim

‘The Commission is empowered to adopt implementing acts, based on the principle of equivalence, concerning the conversion of the yearly average carbon price effectively paid in accordance with paragraph 1 of this Article and of the yearly default carbon prices determined in accordance with paragraph 4 of this Article into a corresponding reduction of the number of CBAM certificates to be surrendered.Those acts shall also govern the conversion of the carbon price expressed in foreign currency into euro at the yearly average exchange rate, the evidence required of the actual payment of the carbon price, examples of any relevant rebate or other form of compensation referred to in paragraph 1 of this Article, the qualifications of the independent person referred to in paragraph 2 of this Article and the conditions to ascertain that person’s qualifications and independence. The qualifications mentioned in the previous paragraph shall include the granting of accreditation by a national accreditation body, the specification of the certification procedures, and the appropriate exchanges of information between the independent person, national accreditation bodies, the European Commission and competent authorities. The Commission is also empowered to regulate the conditions for deducting carbon credits under Article 6 of the Paris Agreement.

View source →

Settled later in secondary legislation. The conversion methodology, the evidence standard and the treatment of Paris Agreement Art. 6 credits all sit in implementing acts that have not been adopted.