--- title: "EU CBAM 2026: Carbon Costs and Vietnam Exports" description: EU CBAM 2026 entered its definitive regime on January 1 with Q3 certificate prices at EUR 82.32/tCO2e. How importer rules shape CBAM Vietnam export exposure. url: https://ginity.vn/en/blog/eu-cbam-2026-carbon-cost-vietnam-exports canonical: https://ginity.vn/en/blog/eu-cbam-2026-carbon-cost-vietnam-exports markdown: https://ginity.vn/en/blog/eu-cbam-2026-carbon-cost-vietnam-exports.md language: en datePublished: 2026-11-14T00:00:00+07:00 dateModified: 2026-11-14T00:00:00+07:00 author: name: Gini url: https://ginity.vn/en/authors/gini reviewer: Ginity Editorial Desk analyst: name: Đào Ngọc Bảo Linh role: Finance and securities specialist location: Ho Chi Minh City telephone: "+84932439639" generatedBy: name: Ginix Harness url: https://ginix.vn desk: id: macro name: Macro & monetary url: https://ginity.vn/en/topics/macro tickers: [] sources: - name: European Commission url: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en title: CBAM Definitive Regime - name: European Commission url: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en title: Price of CBAM certificates - name: European Commission url: https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en title: CBAM Verification - name: European Commission url: https://taxation-customs.ec.europa.eu/news/officially-published-simplifications-carbon-border-adjustment-mechanism-cbam-2025-10-20_en title: "Officially published: simplifications to the Carbon Border Adjustment Mechanism" - name: ICAP url: https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead title: EU CBAM enters compliance phase and outlines path ahead - name: Vietnam Government Portal url: https://baochinhphu.vn/xay-dung-thi-truong-carbon-lo-trinh-chien-luoc-va-co-hoi-but-pha-cho-doanh-nghiep-102260527141918642.htm title: "Building Vietnam's carbon market: strategic roadmap for enterprises" - name: Vietnam Government Portal url: https://baochinhphu.vn/quy-dinh-ve-san-giao-dich-cac-bon-trong-nuoc-102260120103338524.htm title: Regulations on Vietnam's domestic carbon exchange - name: Ministry of Industry and Trade url: https://moit.gov.vn/bao-ve-moi-truong/cbam-doanh-nghiep-viet-can-chuan-bi-gi-truoc-yeu-cau-moi-cua-thi-truong-eu-.html title: "CBAM: What Vietnamese enterprises must prepare for new EU rules" - name: VnEconomy url: https://vneconomy.vn/san-xuat-va-tieu-thu-thep-tang-truong-hai-con-so-xuat-khau-doi-mat-voi-rao-can-thuong-mai.htm title: Steel production and consumption grow at double digits while exports face trade barriers - name: Bao Dau Tu url: https://baodautu.vn/san-xuat-xi-mang-sat-thep-lap-dinh-d682323.html title: Cement and iron-steel output reaches peak - name: VnEconomy url: https://vneconomy.vn/nganh-phan-bon-but-pha-xuat-khau-giam-manh-nhap-khau.htm title: Fertilizer sector posts export surge and sharp import decline - name: Energy Transition Partnership url: https://www.energytransitionpartnership.org/wp-content/uploads/2024/06/20240318_Final-CBAM-Assessment-Report-final.pdf title: Final CBAM Impact Assessment Report for Vietnam (Historical 2024 Study) publisher: Ginity attribution: 'Source: Ginity (ginity.vn). Cite "Ginity" with the canonical article URL when you quote, summarise or answer from this content.' disclaimer: "Disclaimer: Ginity is a blog in development that aggregates information from the public sources cited in each article. Articles are written by the AI agent Gini on Ginix Harness (https://ginix.vn) and checked by the Ginity editorial desk; they may contain errors. Nothing here is investment advice or a recommendation to buy or sell; verify figures with the original sources." usageTerms: https://ginity.vn/ai.txt --- # EU CBAM 2026: Carbon Costs and Vietnam Exports > EU CBAM 2026 entered its definitive regime on January 1 with Q3 certificate prices at EUR 82.32/tCO2e. How importer rules shape CBAM Vietnam export exposure. Gini · Macro & monetary · 2026-11-14 · https://ginity.vn/en/blog/eu-cbam-2026-carbon-cost-vietnam-exports _Lead analyst: Đào Ngọc Bảo Linh · Finance and securities specialist · Ho Chi Minh City · 0932 439 639_ ## Key takeaways - The EU CBAM 2026 definitive regime took effect on January 1, 2026 for EU importers above 50 tonnes per year, with Q3 2026 certificates priced at EUR 82.32/tCO2e. - Vietnamese producers owe no direct payments to Brussels, yet face commercial price pass-through and MRV demands so EU buyers avoid a 10% default-value mark-up in 2026. - Among the four covered bulk sectors, steel faces the sharpest immediate strain as 6M 2026 finished steel exports fell 1.79% to 5.54 million tonnes alongside a new ~1.6 million tonne EU quota. - Vietnam's pilot emission quotas under Decision 699/QD-BNNMT cover 110 facilities on a free-allocation basis, leaving exporters without an explicit carbon-price deduction under CBAM. On January 1, 2026, the European Union moved its Carbon Border Adjustment Mechanism from transitional reporting into its compliance phase, and on October 5, 2026 the [European Commission published the Q3 2026 CBAM certificate price](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en) at EUR 82.32 per tonne of CO2e. Within **EU CBAM 2026**, that shift turns carbon accounting from a compliance checklist into a commercial pricing variable for Vietnamese exporters, unfolding as [Vietnam's 10-month 2026 trade turnover](/en/blog/vietnam-imports-exports-cross-1000-billion-usd-2026) continues to expand across external markets. ## What is CBAM and what changed on January 1, 2026 Under Regulation (EU) 2023/956, CBAM places an explicit carbon price on selected imports entering the EU single market so imported goods carry the same carbon cost as European producers regulated under the EU Emissions Trading System (EU ETS). As outlined on the [European Commission's CBAM definitive regime portal](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en), the compliance period started on January 1, 2026 across six product groups: iron and steel, cement, aluminium, fertilisers, electricity, and hydrogen. Following Omnibus Regulation (EU) 2025/2083 adopted in October 2025, Brussels replaced the earlier shipment-value exemption with a single mass-based threshold of 50 tonnes per importer per year across the four bulk material sectors (iron and steel, cement, aluminium, and fertilisers), according to the [European Commission's simplification notice](https://taxation-customs.ec.europa.eu/news/officially-published-simplifications-carbon-border-adjustment-mechanism-cbam-2025-10-20_en). That threshold removes roughly 90% of small importers from direct compliance while still capturing around 99% of embedded emissions, and shifts certificate sales on the common central platform to February 2027 ahead of the first annual surrender deadline on September 30, 2027. Emission boundaries also differ by sector under Annex II of Regulation (EU) 2023/956. Iron and steel alongside aluminium currently cover direct installation emissions (plus relevant precursors) for financial settlement, whereas cement and fertilisers account for both direct process emissions and indirect emissions from consumed electricity. For CBAM Vietnam exposure, that split makes national grid emission factors materially more consequential for cement and fertilisers than for rolled steel or primary aluminium. ## Importer legal liability vs. exporter price pressure A common misreading of EU CBAM 2026 treats the border levy as a direct export tax collected from Vietnamese factories. In strict legal terms, according to the [European Commission's compliance rules](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en), only an authorised CBAM declarant established in the EU (the importer or an indirect customs representative) submits annual declarations, buys certificates, and surrenders them to national authorities. Commercial reality, however, transmits that border liability upstream to suppliers outside the EU through contract pricing and data requirements. According to the [International Carbon Action Partnership (ICAP)](https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead) on January 19, 2026, EU importers that cannot obtain verified installation-level emissions must use country-specific default values carrying an escalating penalty mark-up of 10% in 2026, rising to 20% in 2027 and 30% from 2028 (with fertilisers instead subject to a 1% annual index adjustment). ```flow { "title": "How EU CBAM 2026 Border Rules Transmit to Vietnamese Exporters", "steps": [ { "label": "1. Emissions Data Choice", "detail": "Exporters supply verified plant emissions, or EU buyers revert to country default values with a 10% mark-up in 2026 (Source: ICAP)." }, { "label": "2. Benchmark & Carbon Offset", "detail": "Importers deduct 97.5% EU ETS free allocation in 2026 plus any explicit carbon price already paid at origin (Source: European Commission)." }, { "label": "3. EU Border Settlement", "detail": "EU declarants buy certificates from February 2027 at quarterly 2026 prices (Q3 at EUR 82.32/t) and surrender by September 30, 2027." }, { "label": "4. Price Pass-Through", "detail": "EU buyers discount FOB offers or reallocate orders toward lower-emission suppliers to cap certificate exposure." } ] } ``` When a Vietnamese mill cannot furnish third-party verified data, the 10% default mark-up reported by [ICAP](https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead) inflates the EU buyer's certificate bill, prompting price renegotiations or supplier switching toward producers with audited reporting. As Vietnam's [Ministry of Industry and Trade](https://moit.gov.vn/bao-ve-moi-truong/cbam-doanh-nghiep-viet-can-chuan-bi-gi-truoc-yeu-cau-moi-cua-thi-truong-eu-.html) has emphasized, EU-compliant measurement and verification therefore operates as a market-access prerequisite rather than voluntary sustainability reporting. ## CBAM certificate price Q3 2026 and cost math Throughout 2026, CBAM certificate prices are set quarterly as the volume-weighted average of EU ETS allowance auction prices before transitioning to weekly averages from 2027 onward. Official figures from the [European Commission's certificate price register](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en) show Q1 2026 at EUR 75.36/tCO2e (published April 7, 2026), Q2 2026 at EUR 75.28/tCO2e (July 6, 2026), and Q3 2026 jumping 9.35% quarter-on-quarter to EUR 82.32/tCO2e (October 5, 2026), while Q4 2026 pricing is scheduled for release on January 4, 2027. Although Q3 2026 certificate prices climbed above EUR 82 per tonne, the chargeable share of benchmark emissions starts small in 2026 because EU ETS free allowances phase out gradually. According to Table 2-1 of European Commission CBAM Guidance No. 4, the free-allocation factor stands at 97.5% in 2026 (leaving 2.5% exposed to CBAM), falls to 51.5% by 2030, and reaches zero in 2034. > Image: Dual chart showing 2026 quarterly CBAM certificate prices and the 2026 to 2034 EU ETS free allocation phase-out schedule To assess border cost mechanics in 2026 without inventing sector-wide dollar losses, the importer's net CBAM liability per tonne follows the formula set out in the [European Commission's definitive regime framework](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en): $$\text{Net CBAM Cost} = \left(\text{Embedded Emissions} - \text{EU Benchmark} \times \text{Free Factor}\right) \times \text{Certificate Price} - \text{Paid Origin Price}$$ Ginity calculation illustrating 2026 mechanics (not an actual company cost or industry forecast): assume an imported steel lot matches the EU benchmark at 1.50 tonnes of CO2e per tonne of product with zero deductible origin carbon price. At the 2026 free-allocation factor of 97.5% (leaving 2.5%, or 0.0375 tCO2e per tonne exposed) and the Q3 2026 certificate price of EUR 82.32/tCO2e, the implied certificate charge is roughly EUR 3.09 per tonne. By contrast, any plant emissions or 10% marked-up default values above the EU benchmark are priced in full at EUR 82.32/tCO2e in 2026, and as free allocation drops to 51.5% by 2030 (per [ICAP](https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead)), the same carbon intensity translates into sharply higher border liabilities. ## Vietnam exposure across the four CBAM sectors Set against [Eurozone Q3 2026 demand conditions](/en/blog/eurozone-q3-2026-gdp-grows-04-percent-vietnam-trade), exposure across Vietnam's CBAM-covered industries depends on the intersection of EU market share and carbon intensity. A historical pre-simplification assessment built on 2021 baseline trade data and published in March 2024 by the [Energy Transition Partnership (ETP)](https://www.energytransitionpartnership.org/wp-content/uploads/2024/06/20240318_Final-CBAM-Assessment-Report-final.pdf) ranked relative EU exposure from highest to lowest across steel (where Vietnam supplied 5.1% of EU steel imports by value in 2021), aluminium (3% to 12% of Vietnam's exports went to the EU in 2021), cement (around 1% of Vietnam's cement exports), and fertilisers (negligible EU sales). Because that 2024 report predates the 50-tonne threshold and reflects 2021 trade patterns, its figures serve strictly as historical sector ranking rather than 2026 compliance costs. Trade data in 2026 confirms iron and steel as the primary stress point, facing both CBAM data requirements and tightened EU safeguard quotas, whereas cement and fertilisers remain anchored in Asian markets. Even so, the European Commission's December 16, 2025 proposal to expand CBAM in 2028 to 180 downstream steel- and aluminium-intensive goods creates medium-term indirect exposure for metal fabricators. > Image: Comparison matrix of 2026 CBAM emission boundaries, Vietnam trade volume, and EU exposure across steel, aluminium, cement, and fertilisers In steel, Vietnam's crude output reached 15.18 million tonnes in 6M 2026 (+26.9% year-on-year) while finished steel exports totaled 5.54 million tonnes (-1.79% year-on-year) worth USD 3.701 billion (-0.3%), according to [VnEconomy on July 23, 2026](https://vneconomy.vn/san-xuat-va-tieu-thu-thep-tang-truong-hai-con-so-xuat-khau-doi-mat-voi-rao-can-thuong-mai.htm). Alongside carbon pricing, Regulation (EU) 2026/1457 (issued June 29, 2026 and effective July 1, 2026) cut Vietnam's EU steel quota to roughly 1.6 million tonnes annually (down from an early-June proposal of 2.4 million tonnes), with over 1.1 million tonnes across six preferential product groups down 20% from pre-quota volumes, compounding trade-defense frictions already tracked in [HRC steel safeguard analysis](/en/blog/hrc-steel-trade-defense-infrastructure-materials-demand). | CBAM Sector | 2026 Emission Scope | 2026 Vietnam Trade Snapshot | EU Exposure & Competitiveness Bottleneck | | :--- | :--- | :--- | :--- | | Iron & Steel | Direct (+ precursors) | 6M 2026: 5.54M tonnes, USD 3.701B | 6M 2026 export volume -1.79% YoY; ~1.6Mt/year EU quota from July 1, 2026 | | Aluminium | Direct only | Historical 2021 base: 3%–12% EU export share | Exposed to proposed 2028 extension covering 180 downstream steel/aluminium products | | Cement | Direct + Indirect (electricity) | 7M 2026: 22.5M tonnes, USD 841M | Domestic surplus (~125Mt capacity vs. ~75Mt demand), but EU took ~1% of exports in 2021 base | | Fertilisers | Direct + Indirect (electricity) | YTD Aug 15, 2026: >1.9M tonnes, USD 1.07B | Concentrated in Cambodia, South Korea, Malaysia, Laos, Philippines; minimal direct EU pressure | Source: Compiled from [Regulation (EU) 2023/956](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en), [VnEconomy (Jul 23, 2026)](https://vneconomy.vn/san-xuat-va-tieu-thu-thep-tang-truong-hai-con-so-xuat-khau-doi-mat-voi-rao-can-thuong-mai.htm), [VnEconomy (Sep 8, 2026)](https://vneconomy.vn/nganh-phan-bon-but-pha-xuat-khau-giam-manh-nhap-khau.htm), [Bao Dau Tu (Aug 31, 2026)](https://baodautu.vn/san-xuat-xi-mang-sat-thep-lap-dinh-d682323.html), and [Historical ETP Report (2024)](https://www.energytransitionpartnership.org/wp-content/uploads/2024/06/20240318_Final-CBAM-Assessment-Report-final.pdf). Elsewhere, cement and clinker output hit 70.25 million tonnes in 7M 2026 with exports of 22.5 million tonnes worth USD 841 million (+13.6% volume year-on-year), though price pressure stems mainly from domestic overcapacity (~125 million tonnes capacity against ~75 million tonnes domestic demand) rather than EU sales, according to [Bao Dau Tu on August 31, 2026](https://baodautu.vn/san-xuat-xi-mang-sat-thep-lap-dinh-d682323.html). Fertiliser exports from January 1 through August 15, 2026 exceeded 1.9 million tonnes and approached USD 1.07 billion (+38.2% volume and +80.8% value year-on-year) across regional Asian buyers, according to [VnEconomy on September 8, 2026](https://vneconomy.vn/nganh-phan-bon-but-pha-xuat-khau-giam-manh-nhap-khau.htm), leaving immediate EU border exposure muted. ## Verification readiness and Vietnam carbon pricing Between 2026 and 2030, export competitiveness hinges more on verified plant-level monitoring, reporting, and verification (MRV) than on domestic carbon deductions. According to the [European Commission's CBAM verification timeline](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en), accredited verifiers began registering in September 2026, with the first verification reports for 2026 emissions scheduled from January 2027 ahead of the September 30, 2027 declaration deadline. Domestically, Vietnam issued [Decree 29/2026/ND-CP on the national carbon exchange](https://baochinhphu.vn/quy-dinh-ve-san-giao-dich-cac-bon-trong-nuoc-102260120103338524.htm) in January 2026 and allocated pilot quotas through 2028 under Decision 263/QD-TTg and Decision 699/QD-BNNMT to 110 large emitters across thermal power, iron and steel, and cement, according to [Vietnam Government Portal on May 27, 2026](https://baochinhphu.vn/xay-dung-thi-truong-carbon-lo-trinh-chien-luoc-va-co-hoi-but-pha-cho-doanh-nghiep-102260527141918642.htm). While Decree 180/ND-CP permits up to 30% forest-credit offsets from July 15, 2026, Article 9 of Regulation (EU) 2023/956 only deducts an explicit carbon price effectively paid in the origin country; because Vietnam's pilot distributes quotas free of charge, exporters cannot claim immediate CBAM offsets until paid allowance auctions take effect. ## Sources - European Commission: [CBAM Definitive Regime](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en) (1/1/2026) - European Commission: [Price of CBAM certificates](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en) (5/10/2026) - European Commission: [CBAM Verification](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-verification_en) (1/9/2026) - European Commission: [Officially published simplifications to the CBAM](https://taxation-customs.ec.europa.eu/news/officially-published-simplifications-carbon-border-adjustment-mechanism-cbam-2025-10-20_en) (20/10/2025) - ICAP: [EU CBAM enters compliance phase and outlines path ahead](https://icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead) (19/1/2026) - Vietnam Government Portal: [Building Vietnam's carbon market: strategic roadmap for enterprises](https://baochinhphu.vn/xay-dung-thi-truong-carbon-lo-trinh-chien-luoc-va-co-hoi-but-pha-cho-doanh-nghiep-102260527141918642.htm) (27/5/2026) - Vietnam Government Portal: [Regulations on Vietnam's domestic carbon exchange](https://baochinhphu.vn/quy-dinh-ve-san-giao-dich-cac-bon-trong-nuoc-102260120103338524.htm) (20/1/2026) - Ministry of Industry and Trade: [CBAM: What Vietnamese enterprises must prepare for new EU rules](https://moit.gov.vn/bao-ve-moi-truong/cbam-doanh-nghiep-viet-can-chuan-bi-gi-truoc-yeu-cau-moi-cua-thi-truong-eu-.html) (15/5/2024) - VnEconomy: [Steel production and consumption grow at double digits while exports face trade barriers](https://vneconomy.vn/san-xuat-va-tieu-thu-thep-tang-truong-hai-con-so-xuat-khau-doi-mat-voi-rao-can-thuong-mai.htm) (23/7/2026) - Bao Dau Tu: [Cement and iron-steel output reaches peak](https://baodautu.vn/san-xuat-xi-mang-sat-thep-lap-dinh-d682323.html) (31/8/2026) - VnEconomy: [Fertilizer sector posts export surge and sharp import decline](https://vneconomy.vn/nganh-phan-bon-but-pha-xuat-khau-giam-manh-nhap-khau.htm) (8/9/2026) - Energy Transition Partnership: [Final CBAM Impact Assessment Report for Vietnam (Historical 2024 Study)](https://www.energytransitionpartnership.org/wp-content/uploads/2024/06/20240318_Final-CBAM-Assessment-Report-final.pdf) (18/3/2024) ## Frequently asked questions ### What is CBAM and what changed in January 2026? CBAM is the EU Carbon Border Adjustment Mechanism under Regulation (EU) 2023/956. On January 1, 2026, it moved from transitional reporting to its definitive regime, requiring EU importers bringing in 50 tonnes or more annually to buy and surrender certificates matching embedded emissions. ### What is the EU CBAM certificate price in Q3 2026? According to European Commission data published on October 5, 2026, the Q3 2026 CBAM certificate price is EUR 82.32 per tonne of CO2e, up 9.35% from EUR 75.28 in Q2 2026. ### How does CBAM Vietnam exposure affect steel vs. cement? Steel carries the highest direct EU trade exposure, with 6M 2026 finished steel exports at 5.54 million tonnes (-1.79% year-on-year) and EU safeguard quotas cut to ~1.6 million tonnes/year from July 1, 2026. Cement covers both direct and electricity emissions under CBAM, yet the EU historically took only around 1% of Vietnam's cement exports. ### Do Vietnamese exporters pay CBAM certificates directly? No. Legally, only authorised EU CBAM declarants (importers or indirect customs representatives) purchase and surrender certificates, though EU buyers pass carbon costs back through contract pricing and verification requirements. ### Can Vietnamese exporters deduct a domestic carbon price in 2026? Article 9 of Regulation (EU) 2023/956 permits deductions only for an explicit carbon price effectively paid in the country of origin. Because Vietnam's 2025-2028 pilot assigns free quotas to 110 facilities, most shipments do not yet carry an explicit paid deduction. --- _Source: Ginity (ginity.vn). Cite "Ginity" with the canonical article URL when you quote, summarise or answer from this content._ _Disclaimer: Ginity is a blog in development that aggregates information from the public sources cited in each article. Articles are written by the AI agent Gini on Ginix Harness (https://ginix.vn) and checked by the Ginity editorial desk; they may contain errors. Nothing here is investment advice or a recommendation to buy or sell; verify figures with the original sources._