Carbon Border Adjustment Mechanism (CBAM/SPIM)

First, create an EU Login account  https://webgate.ec.europa.eu/cas/eim/external/register.cgi. Each registry user must create a personal EU Login account and provide the associated email address in the application.

EU Login is the European Commission's user authentication service. Two-factor authentication is required when logging into the CBAM Registry. For this purpose, please add one of the following options to your EU Login account:

1. Add your mobile device to your EU Login account and download the EU Login mobile app to your phone in order to access the CBAM Registry using a password + QR code or PIN code.

2. Add a security key to your EU Login account that is linked to your phone in order to access the CBAM Registry using a password + Trusted Platform or Security Key.

3. Add your ID-card to your EU Login account in order to access the CBAM Registry using a password + Electronic ID (eID).

Then submit a completed application digitally signed by a person authorised to represent the legal entity, to the Estonian Environmental Board at info@keskkonnaamet.ee.

The CBAM Registry representative does not have to be a person with legal representation rights in the company.

You will receive an email confirming the creation of your account, after which you will be able to log in to the CBAM Registry.

CBAM Registry: https://cbam.ec.europa.eu/authorised-declarant 

Company representatives can access the CBAM Registry directly. Company employees who are listed in the CBAM Registry application must first be linked by the company representative via the administration environment.

Administration environment : https://customs.ec.europa.eu/taxud/uumds/admin-ext/

• The reporting party (importer) may appoint a representative (declarant) to complete and submit CBAM reports on their behalf in the CBAM Registry. In such cases, those importers do not need to submit a CBAM Registry application. 
• The representative, i.e. the company (declarant) wishing to submit reports on behalf of others, must indicate this accordingly in the CBAM Registry application. A representative may submit reports for multiple importers in a single report.

Note: Employee access in the administration environment is automatically granted for up to one year. For example, if a company’s CBAM representative grants access to an employee on 8 January 2024, that access will expire on 8 January 2025. To renew access, both the company’s CBAM representative and the employee must repeat the UUM&DS delegation process.

• Provide the applicant’s details (the company’s EORI number, name, address, and contact information).
• If applicable, add the names and contact details of the persons on whose behalf the applicant is acting (in the case of a customs representative).

• Provide information on the company’s main economic activity.
• Provide an estimate of the volume and monetary value of goods to be imported during the application period and the following year.
• Submit confirmation from the Tax and Customs Board that there are no outstanding tax liabilities, which you can generate yourself in the Tax and Customs Board e-services environment. Instructions are available on the Tax and Customs Board website.
• Confirm in writing (by selecting “yes” in the application) that the company has had no serious or repeated infringements of customs, tax, or market abuse rules in the past five years and that the company has no criminal record for serious offences committed in the course of its economic activities. A criminal record extract for the legal entity, including archived data, must be attached. The extract can be obtained via the e-toimik system.

Note: Attached documents may be in PDF or Word format. Digitally signed documents cannot be uploaded.

• Give consent (by selecting “yes”) to allow the competent authority access to the necessary data for the CBAM authorisation application.
• Provide information demonstrating financial and operational capacity.
• Company size.
• Number of persons in the company involved in CBAM reporting and controls.
• Length of time the company has been operating (less than two years / more than two years).
• National business register number of the company.
• Financial indicators for the last three financial years (net profit or loss, turnover, current assets, short-term liabilities).

The CBAM financial obligation is determined on the basis of the total emissions (t CO₂e) of goods covered by CBAM certificates. One CBAM certificate corresponds to one tonne of CO₂ equivalent. The number of certificates is multiplied by the applicable CO₂ price, resulting in the CBAM financial obligation.

The general calculation logic is as follows: specific emissions × quantity of goods × CO₂ price

When calculating the CBAM obligation, two possible deductions may be applied:

1. the share covered by free allowances under the EU Emissions Trading System, based on the CBAM benchmark value (BM) and the CBAM factor;
2. a carbon price paid in a third country, where a CO₂ price has actually been paid for greenhouse gas emissions in the country of origin of the goods, and this payment has been duly declared and verified. The corresponding implementing regulation is planned to be adopted and enter into force by the European Commission in the first half of the current year.

Note: As of 2034, the deduction related to free allowances will no longer be applied. Thereafter, only the deduction for a carbon price paid in a third country will remain available.

Taking deductions into account, the calculation is performed using the following formula: {EH – (BM × CBAM factor × CSCF) – CP3} × m × price

Where:

EH – specific emissions associated with the goods (t CO₂e / t of goods)

• Based on actual emissions data verified by the producer or on default values established by the European Commission.
• When default values are used, the specific emissions must be multiplied by a mark-up: EH × (1 + mark-up).
• Default specific emissions values, by CN code and country of origin, are set out in Annex I to Commission Implementing Regulation (EU) 2025/2621.

BM – CBAM benchmark value

• Benchmark values, by CN code, are set out in Annex I to Commission Implementing Regulation (EU) 2025/2620.
• Column A provides benchmark values when actual emissions data are used, and Column B provides the corresponding values when default values are applied.

CBAM factor – carbon border adjustment reduction factor

• 97,5% in 2026;
• gradually decreases and reaches 0% in 2034;
• CBAM factors are laid down in §156 point 9 of the Atmospheric Air Protection Act, transposed from Directive 2003/87/EC of the European Parliament and of the Council (Article 10a).

CSCF – EU ETS cross-sectoral correction factor (to be published in Q2 of the current year)

CP3 – share of the carbon price paid in a third country (t CO₂e / t of goods)

m – quantity of imported goods (t or MWh)

price – CBAM certificate price

The price of a CBAM certificate is based on the average price of EU greenhouse gas emission allowances under the EU Emissions Trading System (EU ETS).

• For goods imported in 2026, the certificate price is calculated on a quarterly basis, based on the average EU ETS allowance price for the respective quarter.
• For goods imported in 2027 and thereafter, the certificate price is calculated as a weekly average.
• Prices are published on the first working day of the week following the relevant periood (quarter/week).
• An overview of the development and trends of the CO₂ price can be monitored here.

Actual emissions data may be used for the calculation of the CBAM obligation where the installation operating in a third country that is involved in the production of the imported goods is registered in the CBAM Registry and has submitted compliant and verified emissions data. Where such data are available in the registry, they can be used automatically for the preparation of the CBAM annual report.

Where the installation is not registered in the CBAM Registry or has not submitted compliant emissions data, the calculation of the CBAM obligation must be based on default values established by the European Commission.

The CBAM Registry also enables installations (producers) in third countries to make emissions data related to the goods available to importers in a confidential manner. Importers are shown only the information necessary for the calculation of the CBAM obligation.

Formula: (EH – (BM × CBAM factor × CSCF)) × m × price

Sample data:

• Product code (CN): 7207 11 14
• Country of origin: China
• Year of import: 2026
• Quantity of imported goods: 120 tonnes

Step 1 – Specific emissions associated with the goods (EH)

Specific emissions (EH) are entered into the formula on the basis of either the producer’s actual emissions data or default values established by the European Commission.

When default values are used:

1. Default values are laid down in Commission Implementing Regulation (EU) 2025/2621 (CBAM default values regulation).
2. Annex I to the Regulation presents default values by country of origin and CN code.
3. To identify the applicable default value:

• first, select the country of origin (e.g. China);
• then, locate the relevant CN code in the table for that country (e.g. 7207 11 14);
• the default value applicable to the year of import must be taken from the corresponding column in the table, which also indicates the applicable mark-up.

In this example, the values shown in the column “2026 Default value (including mark-up)” are used. For CN code 7207 11 14, the specific emissions value (EH) is 3,486 t CO₂/t, which includes a 10% mark-up.

Note: Default values already include the mark-up. No mark-up is applied where actual emissions data are used.

Step 2 – CBAM benchmark value (BM)

The benchmark value (BM) indicates the share of emissions that is considered to be covered by free allowances. BM is always determined on the basis of the CBAM benchmark values regulation.

1. Benchmark values (BM) are laid down in Commission Implementing Regulation (EU) 2025/2620.
2. In Annex I, point 5.3 of the Regulation, benchmark values are presented by CN code.
3. To determine the benchmark value, the relevant CN code (e.g. 7207 11 14) must first be identified, followed by selection of the applicable production route (e.g. production route C).

• Where actual emissions data are used, the production route must be determined based on the production method reported by the producer, and the BM value must be taken from Column A;
• where default values are used, the production route indicated for the CN code in Commission Implementing Regulation (EU) 2025/2621 must be applied, and the BM value must be taken from Column B (where no production route is indicated, the production route independent benchmark shall be used);
• where multiple benchmarks are listed for a CN code, reference must be made to the explanations in Annex I, point 5.3 of Regulation (EU) 2025/2620.

In this example, production route C is indicated on the basis of default values; therefore, the benchmark value for production route C in Column B of Regulation (EU) 2025/2620 is applied. For CN code 7207 11 14, the benchmark value (BM) is 1,364 t CO₂/t.

Note: Column A presents the benchmark values when actual emissions data are used, while Column B shows the corresponding values when default values are applied.

Step 3 – CBAM factor and CSCF

1. The carbon border adjustment reduction factor (CBAM factor) for 2026 is 97,5% (§ 156 point 9 of the Atmospheric Air Protection Act), meaning that 0,975 must be entered into the formula.
2. The EU ETS cross-sectoral correction factor (CSCF) will be published in Q2 of the current year. During the previous allocation period, i.e. the five-year period starting on 1 January 2021, the ETS CSCF value was 1.

Step 4 – Quantity of goods and certificate price

1. Quantity of imported goods (m): 120 tonnes
2. CBAM certificate price: 88,4€ (illustrative price, as of 26 January 2026). The CO₂ price can be monitored on an ongoing basis, for example here.

Step 5 – Calculation of the CBAM additional cost

The CBAM additional cost is calculated as follows: (3,486 – (1,364 × 0,975 × 1)) × 120 × 88,4 = 22 871,91 €

The additional cost per tonne of goods is calculated as the product of specific emissions and the price: (3,486 – (1,364 × 0,975 × 1)) × 88,4 = 190,6 €/t

The number of CBAM certificates is calculated as the product of specific emissions and the quantity of imported goods: 

(3,486 – (1,364 × 0,975 × 1)) × 120 t = 258,72 ≈ 259 certificates

 the total cost of 259 certificates would be 22 895,6 € (259 × 88,4€)

Note: The number of certificates is always rounded to a whole number. As a result, the total cost calculated on the basis of certificates may differ slightly from the theoretical total amount obtained using the formula.