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New legislation
CBAM certificate price Q1 2026
On the 7th of April 2026, the European Commission published the CBAM certificate price for Q1 2026: €75.36.
CBAM certificate pricing methodology
The CBAM framework is designed to mirror the carbon cost borne by EU producers under the EU Emissions Trading System (EU ETS). To ensure this alignment, the Commission sets the price of CBAM certificates based on the weighted average of the auction clearing prices of EU ETS allowances.
In 2026, the Commission will calculate and publish four quarterly CBAM certificate prices, each applicable to emissions embedded in CBAM goods imported during the relevant quarter. From 2027 onwards, CBAM certificate prices will be calculated and published on a weekly basis. Each quarterly price in 2026 is calculated during the first calendar week following the end of the relevant quarter, using publicly available EU ETS auction data. All CBAM certificates for CBAM imports in 2026 must be purchased via the CBAM Registry from February 2027.
Published CBAM certificate prices for 2026
- Q1 2026 (published 7 April 2026): €75.36
- Q2 2026: to be published 6 July 2026
- Q3 2026: to be published 5 October 2026
- Q4 2026: to be published 4 January 2027
As these prices are directly relevant for budgeting, pricing strategies, and assessing the financial exposure associated with CBAM covered imports, we do recommend using the Q1 2026 CBAM certificate price to make or update a financial impact assessment.
Modification Section 232 tariffs on steel, aluminum, copper and their derivative products
On 2 April, the U.S. Administration issued a Proclamation updating the manner in which Section 232 tariffs on steel, aluminum, and copper are assessed, with most of the adjusted measures already taking effect on 6 April 2026. The stated objective is to ensure that tariffs reflect the full customs value of imported articles and to introduce clearer, more uniform calculation rules.
In summary, the Proclamation provides as follows:
- Articles made entirely or almost entirely of steel, aluminum, or copper (e.g. steel coils, aluminum sheet) are subject to a flat 50% tariff on the full customs value.
- Derivative articles substantially made of these metals are subject to 25% on the full customs value.
- Certain metal intensive industrial equipment and electrical grid equipment benefit from a reduced 15% rate through 2027, to support industrial capacity expansion in the U.S.
- Products manufactured abroad but made entirely from U.S. origin steel, aluminum, or copper are subject to a lower 10% tariff.
- Products containing 15% or less steel, aluminum, or copper are excluded from Section 232 metals duties.
EU Packaging and Packaging Waste Regulation (PPWR): preparing for major packaging and EPR changes
The new EU Packaging and Packaging Waste Regulation (PPWR) introduces harmonised, EU wide rules covering the full lifecycle of packaging, replacing the existing directive based framework under the Packaging and Packaging Waste Directive. The PPWR applies to all packaging placed on the EU market, regardless of material, sector or sales channel, including packaging supplied by non EU sellers and e commerce platforms.
A key feature of the PPWR is the expansion and uniform application of Extended Producer Responsibility (EPR) obligations. All relevant economic operators — including suppliers, manufacturers, importers, distributors and online platforms — must comply with registration and reporting requirements, with no minimum thresholds applying. In addition, packaging placed on the EU market must meet new design and material requirements, such as limits on empty space, restrictions on certain packaging formats and materials, mandatory labelling of material composition, inclusion of company identification details, recyclability requirements and minimum recycled content targets.
Compliance with selected requirements must be documented through an EU Declaration of Conformity, which manufacturers must prepare and importers must verify and retain. Distributors and online platforms also face additional verification obligations to ensure that EPR requirements have been met before packaging can be placed on the EU market.
The PPWR requirements will be rolled out gradually between 2026 and 2030, introducing new obligations such as producer registration and reporting, uniform EU sorting labels, reuse and refill targets, compostability requirements for specific packaging types, and full recyclability and recycled content obligations. Packaging that does not comply with the PPWR may no longer be placed on the EU market, making early preparation essential.
Businesses involved in manufacturing packaging, placing packaged goods on the EU market or operating online sales platforms should assess their role under the PPWR and develop a clear compliance roadmap to ensure continued market access and regulatory compliance.