22 July 2026 – Once again, right in the middle of the summer recess: a European Commission consultation remains open until 6 August, disguised as a technical detail concerning the purchase and repurchase of CBAM certificates. Yet the Commission also intends to make importers pay for administering CBAM in future, on top of the cost of the CBAM certificates themselves. It is typical of the Commission to schedule consultations of this kind precisely during the political summer recess.
Scandal? Brussels Wants to Make Extra Cash With CBAM
A European Commission consultation remains open until 6 August, disguised as a technical detail. It concerns the purchase and repurchase of CBAM certificates through a new central platform.
Anyone who reads the draft quickly recognises the real message: Brussels intends to make the same companies that are already being asked to pay finance the operation of its carbon border adjustment mechanism as well. The CO2 tax alone is apparently no longer enough. Now even paying the tax costs extra.
Five Cent Fee, Zero Justification
In future, a fee of EUR 0.05 is to be charged for the purchase of every CBAM certificate. Five cents initially sounds insignificant.
By comparison, the EEX, the established trading venue for European emissions allowances, charges a transaction fee of around EUR 0.003 per tonne of CO2. No comparable fee is charged under Germany’s national emissions trading system.
Brussels is therefore setting its fee at roughly sixteen times the rate charged by an established trading venue, while failing to provide any comprehensible justification. No breakdown of costs, no calculation, no evidence. The Commission sets a figure and expects companies to pay.
Across the system, five cents becomes a business model. Based on approximately 440 million tonnes of CO2 embedded in imports subject to CBAM, the fee would generate around EUR 22 million per year. Declarants would pay this money solely for the dubious privilege of being allowed to pay the tax required by law.
Brussels is therefore not merely demanding payment. It is also charging companies for collecting it.
Certificate Buy Back at the Mercy of Brussels
Anyone who has purchased too many certificates may sell them back. The conditions, however, are a bureaucratic affront.
Only one application may be submitted per year. Once submitted, it can neither be corrected nor withdrawn. The administration gives itself up to 42 days to process it.
The authority allows itself six weeks to review the application. The company, by contrast, is not given a single opportunity to correct a transposed digit or data entry error. A typing mistake is not fraud. Yet the draft treats it as though it were an unforgivable offence.
Meanwhile, the overpaid funds remain tied up without interest. One wrong click is enough, and the company bears the loss. The administrative apparatus retains the liquidity benefit created by minimum holding requirements and lengthy processing periods.
Legal Certainty for the Administration in Brussels Only
The legal certainty invoked in the draft appears strikingly one sided.
The platform may correct its reports. Authorities may compare data, investigate discrepancies, and rectify their own mistakes. Only the declarant, who finances the entire procedure, is given a single irrevocable attempt.
The administration claims correction rights for itself while denying them to the party required to pay. This is not a balanced procedural rule. It is institutionally protected convenience.
CBAM Remains a Compulsory Tax
The predictable objection is that CBAM is not a tax.
That is not convincing. CBAM is a state mandated CO2 tax on imports. While Brussels apparently avoids the term, the United Kingdom openly describes its own equivalent as a carbon tax.
A compulsory payment does not become a harmless service merely because it is given a different label. Nor does an additional fee become more transparent simply because it is presented as a technical operating cost.
Trust Without a Cost Breakdown?
The question remains why this institution, of all institutions, should be allowed to impose an opaque compulsory fee.
In May 2025, the General Court of the European Union found that the same Commission had failed to provide a plausible explanation for what had happened to its President’s text messages with Pfizer’s CEO. Anyone unable to provide comprehensible documentation concerning messages linked to contracts worth billions should at least disclose the calculation behind a new fee.
Transparency would not be a concession here. It would be the absolute minimum.
SMEs Pay for the CO2 Tax and the Bureaucracy
In the end, small and medium sized enterprises pay twice: first the tax, then the bureaucracy that collects it.
Brussels once again dresses this up in its usual vocabulary of simplification, efficiency, and sound financial management. That has little to do with the reality of this draft.
Nothing is being simplified. What is efficient is primarily the collection of money. And the only sound assumption is that companies will once again be made to foot the bill.
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