Sale and repurchase of CBAM certificates

This initiative will set out the conditions for the sale and repurchase of CBAM certificates through a common central platform following a joint procurement procedure between Member States and the Commission, which will be public and limited in order to limit this exchange to foster direct environmental integration.

Filed in Italian · English published by the European Commission

Introduction: The European Association of Chemical Distributors (Fecc) supports the EU's climate goals but urges the Commission to align CBAM certificate rules with business realities. Our key recommendations, detailed in our attached paper, are: - Coherent Rollout: All Member States must implement the rules simultaneously to avoid administrative friction and market fragmentation.

Attached document with comments from the Secretariat for Carbon Market of the Brazilian Ministry of Finance (SEMC/MF) and the Secretariat of Green Economy, Decarbonization and Bioindustry of Ministry of Development, Industry, Trade and Services (SEV/MDIC).

Es wurden keine grundsätzlichen Bedenken gegen die Funktionalität der Regelungen des Entwurfs rückgemeldet. Dennoch sind die Unternehmen in einigen Punkten zu weitgehend eingeschränkt und es dürfte der mögliche Sitzwechsel von CBAM-Anmeldern in einen anderen EU-Mitgliedstaat nicht bedacht worden sein.

Çolakoğlu is a scrap-based (electric arc furnace) Turkish steel producer and long-standing EU supplier; our steel carries structurally low embedded emissions. We support CBAMs objective and comment only on the sale/repurchase mechanics, on one principle: the rules should let certificate obligations track real, verified emissions and must not force declarants to over-purchase or forfeit value otherwise the cost is…

Medcem Cement Group welcomes the opportunity to comment on the Draft Commission Delegated Regulation concerning the sale and repurchase of CBAM certificates and the operation of the Common Central Platform. Medcem is a Türkiye based producer and exporter of cement and clinker supplying the European Union market.

NEVIB represents the importers of fasteners and related products in The Netherlands. We actively support making our industry more sustainable but have indicated before that in its current form, CBAM is not the right tool for that, as it is designed for a known group of well-defined base materials products (like steel), and for markets with a limited and number of multinationals trading globally.

VDMA represents around 3,500 member companies of the mechanical and plant engineering industry in Germany and Europe. As many machinery manufacturers rely on globally integrated supply chains and import CBAM-covered materials and components, the practical implementation of CBAM is of significant importance to our industry.

Gerber Steel GmbH, a medium-sized importer and authorised CBAM declarant, submits the attached detailed statement on the draft Delegated Regulation on the sale and repurchase of CBAM certificates and urges the Commission to read it in full.

We act as an authorised CBAM declarant on behalf of several client-importers. We have one practical question on how the draft regulation would work in this situation: One account, many clients : how do we track who owns what? We only have one CBAM account, but we buy and hold certificates for many different clients.

The effectiveness of CBAM will ultimately depend not only on its environmental objectives but also on whether it can be implemented in a practical, proportionate and legally certain manner. Experience gained during the transitional period has shown that this requires implementing rules that are operationally workable, provide legal certainty and avoid unnecessary administrative and financial burdens for importing…

The Spanish Aluminium Association, AEA, acknowledges the Commission's efforts to establish a harmonised and secure framework for the sale and repurchase of CBAM certificates. However, this Delegated Regulation also marks the final operational step towards the full financial implementation of the CBAM without addressing the structural concerns repeatedly raised by the European aluminium industry.

DITH welcomes the opportunity to comment on the draft Delegated Regulation. Please find our comments in the attached file. In summary, while this is a well constructed draft, DITH highlights that the mechanisms outlined risk imposing constraints on financial liquidity of businesses, and the rigidity of the rules around certificate repurchase could create instead of remove regulatory burdens.

Thank you for your opportunity to contribute! Our farmers are widely involved in regulation, mainly through nitrogen-based fertilisers, so the requirements have a direct and indirect impact on their production-related input costs. As the topic is very complex and complex, it would be worthwhile to look at the circumstances in which the use of a common platform is most beneficial.

Filed in Hungarian · English published by the European Commission

CLECAT, the European association representing freight forwarders, customs agents and logistics service providers, welcomes the opportunity to comment on the draft Delegated Regulation on the sale and repurchase of CBAM certificates.

Donalam welcomes the opportunity to provide feedback on the draft Regulation concerning the sale and repurchase of CBAM certificates. From an importers perspective, we would like to highlight the following practical aspects that could improve the clarity, predictability and functioning of the proposed mechanism. 1. Art.

Energy Traders Europe (ETE) represents more than 180 members active across European gas, electricity, carbon and associated markets. Our response below focuses on the operational workability of the CBAM platform and aims to ensure a secure, cost-efficient, transparent and predictable framework for the sale and repurchase of CBAM certificates. Key messages: 1.

The Verband Deutscher Metallhändler und Recycler e.V. (VDM) welcomes the opportunity to comment on the draft Delegated Regulation regarding the sale and repurchase of CBAM certificates and the operation of the Common Central Platform as part of the public consultation (Have your Say).

Filed in German · English published by the European Commission

The Business for CBAM Coalition welcomes the opportunity to comment on the draft Delegated Regulation Position on the sale and repurchase of CBAM certificates. Our members include producers and importers of CBAM goods, among them authorised CBAM declarants who will operate the system this act creates. Only a CBAM that is workable in practice for all parties involved can be a strong CBAM.

1. Increase Flexibility for the Repurchase of CBAM Certificates Recommendation: Allow declarants greater flexibility in submitting or amending repurchase requests, including the possibility of correcting, modifying, or withdrawing requests within a specified period. Rationale: The current draft provides that a repurchase request may only be submitted once per year and, once submitted, cannot be amended or withdrawn.

BMW Group supports implementing rules that enable efficient and proportionate operation of the CBAM certificate system. Key priorities are group-level certificate management, standardized API connectivity, quarterly repurchase opportunities, timely processing of repurchase requests, and transparent certificate allocation and pricing rules.

We welcome the Commissions initiative to establish a clear and harmonised framework for the sale and repurchase of CBAM certificates and for the functioning of the Common Central Platform. From an operational perspective, however, we believe that certain aspects of the proposed rules would benefit from further clarification in order to ensure their consistent and effective implementation by authorised CBAM…

Feedback in the attached document. Technical trade is the import and sales of raw materials, parts, components, machines and systems, as well as the supply of related solutions and services for manufacturing and building industries. The Association of Finnish Technical Traders comprehensively represents the entire technical trade and actively promotes its interests.

CarbonChain is a carbon accounting and CBAM compliance platform for authorised declarants in steel, fertiliser and aluminium. We welcome the draft Delegated Regulation and offer five recommendations. On the single annual repurchase request, we ask that partial repurchase be permitted (residue keeping its lot price), that the declarant nominates the lots, that the Article 23(2) cap is shown before commitment, and…

1- At present, there is a lack of accredited verifiers and no clear verification criteria for operators. This creates significant uncertainty as to whether suppliers will successfully pass the verification process and what the outcome will be. Therefore, importers should have the option to purchase a larger quantity of CBAM certificates as a reserve to protect themselves against this uncertainty.

HSE Group welcomes the opportunity to contribute to the Draft Delegated Regulation setting out conditions for selling and repurchasing CBAM certificates through a common central platform. HSE Group welcomes the Commission's efforts to establish a predictable and robust legislative framework for the implementation of the CBAM.

IETA welcomes the opportunity to provide feedback on the draft Delegated Regulation on the sale and repurchase of CBAM certificates. Our response focuses on practical implementation issues, including delegated execution and group-level operational support, the repurchase process and limits, transaction fees, and areas where further clarification would improve certainty and workability for authorised CBAM declarants.

On behalf of the Ministry of Environment, Taiwan, we welcome the opportunity to share our feedback and contribute toward a robust and effective EU CBAM. In our view, it is vital that the future regulatory framework balance environmental integrity with predictability, proportionality, and compliance with international trade obligations.

Section 13 Payment, Subsection (3) stipulates that the payment for CBAM certificates on the platform must be made exclusively in Euros () to mitigate exchange rate risks. However, it does not specify a clear and standardized exchange rate reference for repurchases or for converting the carbon price paid in the country of origin into Euros (), which is necessary to ensure accuracy and fairness when deducting such…

We, the Japan Iron and Steel Federation, is a nationwide representative body of the Japanese steel industry and its members consist of the country's major iron and steel producers, trading companies, and organizations engaged in steel distribution.

Equiterra Capital submits this response as a sovereign-finance advisor, not as a CBAM-covered importer. Our lens is the Carbon Markets for Global Equity (CM4GE) framework, which treats carbon as a state-administered fiscal instrument and Article 6 of the Paris Agreement as the international settlement layer. The draft Delegated Regulation gets the architecture right.

Hettich Group, a family-owned manufacturer of furniture fittings with more than 8,000 employees worldwide, produces hinges, drawer systems, sliding-door systems and related products. Steel is the dominant raw material in almost every product we make. We are headquartered in Germany and supply customers in more than 80 countries.

Very difficult to pay a customs duty. Requires a lot of resources and risks stealing smaller businesses. The complexity of carrying out the calculations creates a high risk of inaccurate calculations and distortion of competition. It is difficult to predict what the cost will be.

Filed in Swedish · English published by the European Commission

This submission presents the comments of Hyundai Steel Company, established in the Republic of Korea (South Korea), Hyundai Steel Slovakia s.r.o., and Hyundai Steel Czech Republic s.r.o. (collectively referred to as the Hyundai Steel Group or HSG).

INTERFER welcomes the opportunity to comment on the draft Delegated Regulation. As a German-based steel trading company and an authorised CBAM declarant, we support the climate objectives of CBAM but believe that its implementation must remain workable, predictable and proportionate in practice.

The Ministry of Economic Affairs, R.O.C., has consolidated the comments and practical concerns raised by relevant Taiwanese industries regarding the draft Delegated Regulation on the sale and repurchase of CBAM certificates. The Ministry respectfully submits the attached comments and requests for clarification for the European Commissions consideration. Further details are provided in the attached document.

Subject: Comments and Recommendations on the Draft Commission Delegated Regulation regarding the Management of the Sale and Repurchase of CBAM Certificates on the Common Central Platform Submitted by: Thailand Greenhouse Gas Management Organization (Public Organization) TGO Ministry of Natural Resources and Environment, Thailand Executive Summary & Context Thailand remains fully committed to achieving Net-Zero…

The establishment of a Common Central Platform for the purchase and repurchase of CBAM certificates is an important step towards the effective implementation of the Carbon Border Adjustment Mechanism (CBAM). However, I believe that the platform should evolve beyond a transactional payment system into a comprehensive digital compliance ecosystem supporting both economic operators and competent authorities.

The Europe India Centre for Business & Industry (EICBI) welcomes the European Commission's proposal to establish clear rules governing the sale and repurchase of Carbon Border Adjustment Mechanism (CBAM) certificates. As businesses prepare for the definitive phase of CBAM, the operational framework will become just as important as the legislation itself.

Enel supports the CBAM as a necessary complement to the EU ETS to address carbon leakage, preserve a level playing field between EU and non-EU producers, and safeguard industrial competitiveness, while maintaining a strong and predictable carbon price signal.

1. The company alpha aluminium GmbH supports the objectives of the Carbon Border Adjustment Mechanism (CBAM) and the European Union’s efforts to prevent carbon leakage. At the same time, we see considerable practical and economic risks for small and medium-sized importers in this draft. The project significantly shifts financial, organisational and technical risks to the undertakings concerned.

Filed in German · English published by the European Commission

We support a level playing field and effective measures against carbon leakage. However, the mechanism must not be designed in such a way as to impose a disproportionate burden on small and medium-sized importers, to commit capital and to generate significant additional bureaucracy without creating additional climate benefits.

Filed in German · English published by the European Commission

The European Wholesale Trade Association for Semi-finished Metal Products Wirtschaftsver-band Großhandel Metallhalbzeug e.V. (WGM) represents European companies that trade in se-mi-finished metal products made of aluminium, copper and steel alloys.

Following points in the delegated act should be reconsidered: The purchase of CBAM certificates should be free of processing fees. The repurchase of certificates should be made more flexible. There should be a quarterly repurchase option. The deadline for accepting the repurchase of certificates by the competent authority should be less than 42 days.

Contribution to the Carbon Border Adjustment Mechanism (CBAM) Sale and repurchase of allowances The Würth Group is grateful for the opportunity to comment and would like to draw attention from business practice to aspects of the current draft that are crucial for a workable and legally certain implementation without compromising the instrument’s objective.

Filed in German · English published by the European Commission

We find the suggested mechanism relatively reasonable. Nevertheless, we believe that presented as a fixed administrative fee, the 0.05 charge per certificate under Article 15(1) functions in practice as a de facto tariff. Because the total amount increases in direct proportion to the number of certificates issued, the financial burden falls most heavily on large industrial exporters.

EUROFER supports the single annual repurchase slot as set in Art 4.2 for the reasons stated in recital 17. As clarified in this recital, "allowing authorised CBAM declarants to enter multiple repurchase requests into the CBAM registry would increase administrative complexity, hinder effective control and enable optimisation strategies aimed at profiting from price fluctuations over time.

CBAM certificates do not have an unlimited lifespan. Certificates that are not used or redeemed within the applicable time limits may be canceled. For the system to function in practice, the central platform must therefore be able to display, for example: the number of certificates in the account, when they were purchased, which ones are used first (e.g., according to a FIFO principle, first in, first out, if that…

EURANIMI, the European Association of Non-Integrated Metal Importers & Distributors, welcomes the opportunity to comment on the draft Delegated Regulation governing the sale and repurchase of CBAM certificates and the operation of the Common Central Platform.

Good afternoon, when buying and repurchasing certificates, the following questions arise: 1. Do I have to obtain the certificates on the basis of the default value values, of which 50 %? 2. What happens if the current values (SEE-SEFA) differ significantly from the default values? For example, for Indian steel with a default value of 4.708 – 1.491 = 3.217 allowances.

Filed in German · English published by the European Commission

Feedback on the draft Delegated Regulation on the sale and repurchase of CBAM certificates We welcome the creation of a uniform and safe procedure for the sale and repurchase of CBAM certificates. However, from the point of view of importers and their representatives, several provisions need to be adapted.

Filed in German · English published by the European Commission

The draft Delegated Regulation establishes a centralised, traceable and technically integrated framework for the financial management of CBAM certificates. From Vezirhan Çimentos perspective, the principal requirement is to ensure that, although a third-country producer is not a direct party to the certificate transaction, the emissions data, certificate calculation and any cost passed through to its products remain…

Seravon Labs LLC (Wyoming, United States), operating through its European advisory brand Veridex Carbon, provides carbon compliance and CSRD advisory services to exporters and manufacturers across the AfricaGCCEurope trade corridor. We welcome the Commission's consultation on the delegated regulation governing the sale and repurchase of CBAM certificates.

Ciments Terraferma is a spanish company that produces locally cements and imports from countries outside EU part of the raw materials, especially clinker. Ciments Terraferma belongs to the European SME Cement Association (ESMECA). As representatives of independent and medium-sized cement producers operating grinding plants across Europe, ESMECA strongly supports the objectives of the CBAM.

Once again the Commission tries to exceed their mandate under Article 20 of Regulation 2023/956. Article 20 authorizes the Commission to regulate matters related to the timing, administration, fees and operation of the Common Central Platform, the draft goes considerably further by introducing appeal mechanisms, deemed consent provisions, restrictions on repurchase rights, procedural consequences for non-compliance…

The calculation and purchase of CBAM certificates significantly hampers trade in Finland. It seems unfair to pay CBAM costs in Finland, even though actual emissions always occur outside the EU in the country of manufacture, where they have to be paid. It is useful to have the CBAM cost formula in Excel and, for that purpose, to have a formula in which the customer puts the imported kilos per year.

Filed in Finnish · English published by the European Commission

The Federation of German Wholesale, Foreign Trade and Services (BGA) represents companies from the German wholesale, foreign trade and business services sectors. Our members account for a substantial share of Germany's imports and exports and include numerous companies already directly affected by the Carbon Border Adjustment Mechanism (CBAM), as well as many that will become subject to CBAM as its scope expands.

In order to make the process acceptable and effective for both businesses and the administration, we consider it important to: to be able to amend requests for the purchase of certificates before payment (simpler than cancelling and recreating the request for purchase), to make requests for the purchase of certificates by the Administration more flexible: by not imposing an annual buy-back limit or at least allowing…

Filed in French · English published by the European Commission

The European SME Cement Association represents a group of independent and medium-sized cement companies operating across the European Union, including Cementos El Molino (Spain), Cementos La Cruz (Spain), Cementos La Unión (Spain), Cemminerals (Belgium), CemInEu (France), Ciments Terraferma (Spain), Diano Cementi (Italy), and OBrien Cement (Ireland).

Cemminerals is a Belgian family owned cement company with a production plant in Gent and 10% market share in Belgium. We are implicated by the CBAM as part of our raw materials (cement clinker) are imported from outside Europe. As part of the European SME Cement Association (ESMECA), we strongly support the vision of CBAM: ensure that imported products face carbon costs equivalent to those born by EU producers.

Cem'In'Eu is a French company that produces locally cements and imports from countries outside EU part of the raw materials, especially clinker.Cem'In'Eu belongs to the European SME Cement Association (ESMECA). As representatives of independent and medium-sized cement producers operating grinding plants across Europe, ESMECA strongly supports the objectives of the CBAM.

The common CBAM platform should ensure transparent certificate pricing, clear purchasing and repurchase procedures, and seamless integration with verified installation level emissions data. Clear technical guidance should also by provided to both EU importers and non-EU producers to support accurate reporting, reduce administrative burden and improve compliance across the supply chain.

Although the document is really well-thought but taking the leverage of space, I shall be brief about the concerns I see as minor flaws. Addressing them could make the mechanism more robust and successful. While EU competent authorities enjoy protective, multi-day cushions to evaluate requests (e.g., 42 calendar days under Article 4(6)), third-country installations are subjected to uncompromising, automated…

This legislation and draft are way too complex not only for big players but above all for SME's. Besides, the impact on the cash flow of SME's is very harmful, especially when they don't have the possibility to buy their steel in Europe (the Commission forgot to make exceptions for some types of steel that cannot be purchased in Europe).

Contributor: Dean Chapman, Inventor, Veritas Core 1. Executive Summary: The Technical Fallacy of Interface-Level Security The draft delegated regulation correctly emphasizes that robust digital security is paramount for the continuous, automated lifecycle of CBAM certificates across the common central platform and the CBAM registry.

The draft delegated regulation is necessary to make the sale and repurchase of CBAM certificates operational through the common central platform. However, some provisions should be strengthened to ensure proportionality, legal certainty, transparency and adequate protection for authorised CBAM declarants acting in good faith. Transparency on the fee The draft sets a fixed fee of EUR 0.05 per CBAM certificate sold.