Article 9 of Regulation (EU) 2023/956 allows the CBAM cost to be reduced by the effective carbon price already paid in the country of origin. A qualifying scheme must be: (1) legally binding and enforced, (2) cover the same sectors and emissions as CBAM, (3) not include export rebates. Commission Regulation (EU) 2025/2620 specifies eligible instruments.
Key finding (May 2026): No country formally recognized yet
As of May 2026, the European Commission has not issued formal recognition of any third-country carbon pricing scheme under Article 9. EU importers cannot self-certify — a Commission implementing decision is required before any deduction can be applied.
| Country | Scheme | Price | Status |
|---|
| South Korea Best candidate — absolute cap, covers steel. Commission recognition pending. | K-ETS (since 2015) | ~€15–25/tCO2 | Pending |
| Switzerland Effectively exempt under Annex III of the CBAM Regulation. | Swiss ETS (EU-linked) | ~€70/tCO2 | Exempt |
| United Kingdom Qualifying type but not yet formally recognized by Commission (as of May 2026). | UK ETS | GBP 40–60/tCO2 | Pending |
| China Does not qualify: intensity-based; steel sector excluded from CN-ETS. | CN-ETS (electricity only) | ~€10–15/tCO2 | No |
| Turkey No qualifying carbon price. Faces full CBAM cost on all steel exports. | None (ETS in development) | €0 | No |
| India Does not qualify: not nationally mandated or operational at scale. | CCTS (pilot, not operational) | ~€1–2/tCO2 | No |
| USA California cap-and-trade (~€25/t) applies only to California-based facilities. | No federal carbon price | €0 federal | No |
| Russia Does not qualify. No effective carbon pricing mechanism. | Token levy (no enforcement) | ~€0 | No |
What this means in practice: Importers sourcing from South Korea should document K-ETS costs at the installation level now — if the Commission issues formal recognition before the 30 September 2027 declaration deadline, retroactive application may be possible. Turkish steel (the EU's largest single CBAM-affected import source) faces the full CBAM cost with no deduction. China's steel exports similarly have no qualifying deduction, as the CN-ETS covers only electricity.
Source: CBAM Guide, The Trade Hub, Commission Reg. (EU) 2025/2620, DG TAXUD CBAM page — data as of May 2026.