EPD & CBAM Quarterly Outlook — Issue 1: 2026 Q3

This is the first issue of the EPD & CBAM Quarterly Outlook. Every issue has three parts: the quarter’s certificate price, the quarter’s regulatory developments, and three observations through a verifier’s lens. Short, sourced, quarterly.

1. Price: €82.32/tCO₂e — the first clear move of the year

The European Commission published the third quarterly CBAM certificate price on 5 October.

Period	Price (€/tCO₂e)	Published	Change
Q1 2026	75.36	7 April 2026	—
Q2 2026	75.28	6 July 2026	−€0.08
Q3 2026	82.32	5 October 2026	+€7.04 (9.4%)

After two quarters flat around €75, the price followed EU ETS auction prices upward in Q3. The consequence is simple: a product carrying 1 tCO₂e of embedded emissions per tonne cost about €75 in certificates for Q2 imports and about €82 for Q3 imports. For goods declared with default values, every tonne of gap between the default and actual data became more expensive at the same rate.

Timeline: the last quarterly price of 2026 (Q4) comes on 4 January 2027. From 2027 the Commission publishes weekly prices, and from February 2027 certificates are bought on a common central platform. Weekly pricing removes the “fixed cost for the quarter” predictability — 2027 budgets should be built accordingly. Source: Commission — Price of CBAM certificates; detail: our news item.

2. The quarter’s developments (July–September 2026)

EU CBAM

• Default values corrected — Implementing Regulation (EU) 2026/1740 corrected errors in the definitive-period default values, applying from 1 January 2026. EUR-Lex
• Definitive-period guidance documents (14 August) — the Commission’s general, sectoral and electricity guidance. Commission
• Verification and accreditation guidance (24 August) — a 141-page, non-binding guide covering the verification timeline, materiality threshold, site visits and the preceding-production-year rules. News · Commission
• Registry opened to verifiers (1 September) — accredited verifiers register within two months of accreditation; verification reports are issued through the registry from January 2027. News
• Scope extension — Council and ENVI positions on bringing steel- and aluminium-intensive intermediate and finished goods (bolts, wire, springs, household articles) into scope; plenary vote in the September session. Commission
• DS639 — Russia’s WTO panel request against CBAM. WTO

CPR / EPD

• The CPR ties environmental sustainability to AVS 3+ — Delegated Regulation (EU) 2026/1310 (28 August): notified-body verification and factory inspection for all product families. How existing EPDs will be recognised is not yet settled. News · EUR-Lex
• EN ISO 14025:2026 — the revised standard asks programme operators to define re-assessment and update procedures and what counts as a “significant change”; ECO Platform is preparing a common technical note on the ±10% rule in EN 15804+A2. ECO Platform
• EPBD Annex III — Delegated Regulation (EU) 2026/52 sets a common framework for calculating the life-cycle GWP of new buildings. EUR-Lex
• ECO Portal API — the XML interface is being retired; new pricing from November. ECO Platform

Türkiye

• TR-ETS Regulation (27 August) — verification of greenhouse gas reports becomes mandatory; verification bodies must be accredited by TÜRKAK to ISO/IEC 17029. Pilot period: 2026 reporting, first surrender in 2027. Official Gazette (PDF)
• Ministry of Trade announced the CBAM verification guidance and updated its green-transition financing document. Ministry of Trade
• Türkiye Wealth Fund published its first Sustainable Finance Framework (31 August). TWF

One field note from the last week of the quarter: the Jordan LCA/EPD capacity project launched in Amman on 29 September — a sign that environmental data for exports is now a regional agenda.

3. Three observations through a verifier’s lens

1 — With the price up, the “actual data” question became a financial one. With the Q3 price, every tonne of gap between a default value and verified actual data costs about 9% more. The real obstacle we see is not the calculation but traceability: plant data that can be followed back to the meter, the invoice and the stock record. Once weekly pricing starts in 2027, that gap will be repriced every week; building data readiness before the price rises is cheap, building it afterwards is expensive.

2 — The CBAM verification infrastructure became concrete this quarter; the questions arrive in 2027. Guidance (24 August), the registry opening to verifiers (1 September) and verification reports through the registry from January 2027: the chain is complete. For an exporter this means the questions a verifier will ask in 2027 are already known — the monitoring methodology document, data flows, the materiality threshold, the site visit. Those answers are prepared while data is collected, not while the report is written. TR-ETS making verification mandatory in the same quarter means the same plant data will pass through two separate verifications; data discipline built once carries both.

3 — On the EPD side, the “publish and forget” era is closing. The CPR tying environmental sustainability to AVS 3+ (2026/1310) and EN ISO 14025:2026 asking for update procedures point the same way: existing EPDs stop being static documents with an expiry date and enter re-assessment and additional verification cycles. How existing EPDs will be recognised under the CPR is not yet clear; but listing today which EPD was published under which PCR version, with which data year and which validity date, means the first task of the transition is already done when it arrives.

Next issue: with the publication of the Q4 2026 price (4 January 2027) — and we will reset the series’ rhythm for 2027 around weekly prices.