Recently, a draft document outlining preliminary benchmarks for the EU CBAM was circulated among market participants, along with the accompanying Implementing Act concerning the calculation of adjustments to the free allocation relative to the number of CBAM certificates required for surrender. The implementing act for the Carbon Border Adjustment Mechanism (CBAM) benchmarks contains two columns: one for use with actual emission intensities and one for use with default emission factors.
The European Commission is scheduled to publish the methodology for calculating actual emissions and the list of default emission factors before the end of Q4 this year. The provisional CBAM benchmarks will be replaced by definitive CBAM benchmarks after the EU ETS benchmarks for the period from 2026 to 2030 become available.
Our team has analyzed the preliminary benchmarks and they are largely in line with expectations outlined in the EU ETS phase 4 legislation. To obtain our more detailed analysis and forecast information, please contact us about our Market Intelligence subscription packages.
The EU ETS benchmarks for 2026-2030 will form the basis of CBAM benchmarks, as stated in the draft Implementing Act. ‘EU ETS benchmarks are determined for the periods from 2021 to 2025 and from 2026 to 2030. In order to ensure equal treatment of imports, the CBAM benchmarks to be applied in the period from 2026 to 2030 should be based on the EU ETS benchmarks applicable during that period. Furthermore, the factor used for calculating the free allocation of process emissions sub-installations in the EU ETS from 1 January 2028 will be different from the value used until 2027. Therefore, CBAM benchmarks based on a process emissions fallback approach should take this change into account.’
The shift from reliance on global average defaults to the stricter, ETS-aligned benchmarks establishes a more demanding baseline for importers. To avoid a significant increase in their CBAM certificate obligations starting in 2026, non-EU producers must now demonstrate emissions intensities close to those of the EU's best performers using verified actual data.
Since Monday, the EUA Dec-25 contract has been on a roller coaster ride. It fell by EUR 1 to EUR 80 after market opening and spent most of the session defending this key level. In our view, this was mainly driven by profit-taking ahead of Wednesday’s November option expiry and rolling over of Dec-25 positions to 2026 contracts. On Tuesday morning, the Dec-25 contract was lifted by the gains in TTF gas on unplanned Norwegian outages and statements of 'Germany faces gas supply shortage risk this winter' by gas storage lobby Ines. There are also reportedly high trading volumes on Dec-25/Dec-26 spreads, indicating further rolling of positions.In the near term, cold weather will remain a supportive factor for fossil-fired generation and EUA demand, with further volatility com
ing from year-end trading strategies related to the expiry of December futures and options. Key option strike prices of EUR 80 and 85 will remain main magnets. Moreover, another key event to watch is the update on the cancellation of 2026 EUA auction volumes to account for the difference between Maritime’s covered 2024 emissions and the increase in 2024 ETS cap.
ClearBlue Markets will continue to closely monitor upcoming releases of CBAM implementing acts to keep our clients informed of any key developments. Reach out to learn more about our services.