August may have emptied European offices, but it did not slow the EU's trade and carbon-policy calendar. Between 1 July and 28 August, EU institutions changed steel import access, fixed a new quarterly CBAM price, proposed a different path for the EU Emissions Trading System (EU ETS), replaced part of the legal data used in CBAM calculations and published more than 750 pages of implementation, verification and Registry guidance.

July changed market access, prices and policy direction

The new EU steel import measure began applying on 1st July. It replaced the expiring safeguard with 18.3 million tonnes of annual duty-free tariff quota and a 50% duty above the available quota. The detailed country allocations arrived immediately before implementation, after some third-quarter cargoes had already been contracted or shipped. During July, several product-origin quotas filled rapidly and some traders diverted cargoes away from the EU. Our analysis of steel quota exhaustion and cargo rerouting explains why quota availability on the customs-clearance date can outweigh the commercial terms agreed months earlier.

On 6 July, the Commission published the Q2 2026 CBAM certificate price at €75.28/tCO2e, only €0.08 below Q1. The common price does not make every importer equally exposed: the certificate obligation still depends on the embedded-emissions value and the free-allocation adjustment. The Q2 certificate-price analysis covers how the reference enters calculations for goods imported between April and June.

The same day, the European Parliament's Environment Committee adopted its position on extending CBAM to downstream goods and strengthening anti-circumvention rules. This was not the final law. Parliament still needs to complete its position and negotiate with the Council. The committee text nevertheless gives importers an indication of where the next scope debate is heading, including processed steel and aluminium goods and tighter treatment of slight processing used to avoid CBAM. We reviewed the ENVI position and its proposed downstream reach when it was adopted.

On 9 July, the Commission opened feedback on the draft operating rules for buying and repurchasing CBAM certificates. The draft connects requests entered in the CBAM Registry with euro payments on the common central platform, proposes a €0.05 fee for each certificate purchased and limits an ordinary declarant to one repurchase request per year. These rules concern the cash movement that begins when certificate sales open in February 2027. Our article on the draft certificate sale and repurchase process follows the sequence from a purchase request to payment and certificate availability.

On 15 July, the Commission changed its import-monitoring methodology. The import barometer now looks for sustained growth in imports at falling unit values using Eurostat data at eight-digit Combined Nomenclature (CN8) level. It is a screening instrument for trade pressure associated with industrial overcapacity. A listed code does not by itself prove dumping, subsidisation, injury or customs undervaluation. The distinction between that signal and a legal trade-defence finding is developed in our EU import barometer analysis.

The largest policy proposal arrived on 17 July with the Commission's EU ETS review. The proposal would alter the post-2030 emissions cap, redesign parts of the Market Stability Reserve and slow the withdrawal of free allocation for CBAM sectors. If adopted in its current form, the CBAM-linked transition would run until 2038 rather than end in 2034. Current law remains binding while Parliament and Council negotiate. MATERIA incorporated the proposal into its probability-weighted EUA price forecast, because a different allowance-supply path affects the price reference used by CBAM and the benchmark adjustment applied to imports.

July closed with two implementation signals. The Commission's 24 July accreditation update reported that 24 national accreditation bodies had agreed to provide CBAM accreditation and 13 were ready to accept applications. On 30 July, the Commission opened the first product-scope consultation under the steel measure, with responses due by 28 September. The consultation can lead to changes in the products covered by the quota regime, while the accreditation figures determine how quickly the market can build enough verifier capacity for actual-emissions claims.

August replaced legal data and connected verification to the Registry

On 31 July, while many offices were moving into holiday mode, the Commission released replacement CBAM default-value and precursor annexes. They entered into force on 3 August and apply retroactively from 1 January 2026. The replacement corrected missing and erroneous values, production-route indicators and product classifications. It also moved selected cement and clay distinctions to ten-digit TARIC codes where CN8 was too broad.

MATERIA compared the old and corrected tables row by row. The replacement contains 12,823 rows, and 837 of 12,814 matched records change at least one direct, indirect or total-emissions value. A corrected route can also alter the benchmark used for the free-allocation adjustment even where the total-emissions figure stays unchanged. Any 2026 estimate made with the original annexes therefore needs to be rerun against the corrected CBAM reference data.

On 14 August, the Commission published ten definitive-period CBAM guides: four general documents and six sector guides covering cement, hydrogen, fertilisers, iron and steel, aluminium and electricity. The package runs to approximately 470 pages. It changes no legal obligation. Its contribution is practical: worked examples, monitoring instructions and a common reading of the emissions methodology and free-allocation adjustment. Our review of the definitive-period guidance identifies what the documents clarify and which policy questions remain unresolved.

On 24 August, the Commission published 141 pages of guidance for CBAM verifiers and national accreditation bodies. It explains the audit needed before a non-EU installation's emissions can be reported as verified actual values. A first verification normally requires a physical site visit. Where a complex good contains a CBAM precursor produced elsewhere, the downstream calculation may depend on a verified report from the upstream installation.

Accredited verifiers can seek access to the CBAM Registry from 1 September 2026, and the first Registry verification reports are expected from January 2027. The first annual declaration is due on 30 September 2027, but importers that wait until then to contact suppliers may not have enough time to arrange site visits and verify upstream precursor data. Our technical analysis of the verification and accreditation guidance examines site visits, precursor reports and the emerging accreditation capacity.

The Commission then published the 146-page manual for the Operators of Third-Country Installations (O3CI) Portal on 27 August, followed by two verifier access guides on 28 August. These documents describe how the audit moves through the Registry. A verifier first needs accreditation, then technical access and business registration approved by the competent authority. The operator and verifier must also activate a collaboration before the verifier can review the installation's annual emissions information.

The portal manual explains the permissions and data connections needed to use the rules already published. A saved emissions entry has not yet been verified, and an accepted collaboration only gives the verifier access to the installation information. Our new analysis of the CBAM Registry for non-EU operators and accredited verifiers follows the process from registration to the report that the authorised declarant will retrieve.

What requires action after the holidays

The corrected default-value annexes and the steel quota regime already affect 2026 imports. Default-based CBAM estimates should use the replacement dataset, while steel purchases should be tested against quota availability at the expected customs-clearance date. The Q2 CBAM certificate price is fixed for April-June imports and can be used in current accruals.

The ETS review and downstream CBAM extension should remain scenario assumptions until the legislative process is complete. A forecast may assign probability to their adoption, but a compliance calculation cannot replace the law currently in force with a Commission or parliamentary proposal.

The August guidance gives operators and verifiers a practical benchmark for judging whether a monitoring system can support an actual-emissions claim. The later Registry documents add the digital route for sharing that evidence. Importers intending to avoid defaults should confirm that the supplier has registered the correct installation, selected an accreditation route and established the necessary Registry connections early enough for the verifier to complete the audit.

Nobody returning from holiday needs to read every page released during the summer.