CBAM default values vs actual emissions: which to use
Embedded emissions can be declared in two ways: with actual values calculated by the producing installation and verified by an accredited verifier, or with the default values published by the Commission. Default values are simple but carry a penalty mark-up that grows every year.
Default values
Default values are set per country of origin and CN code in Annex I to Implementing Regulation (EU) 2025/2621, based on the average emission intensity of producers in that country. For countries without reliable data, or where a field shows “–”, the value for “other countries and territories” applies, which is set at a high level. Browse them on default values by country.
A mark-up is built into the published values:
| Year of import | Cement, steel, aluminium, hydrogen | Fertilisers |
|---|---|---|
| 2026 | 10 % | 1 % |
| 2027 | 20 % | 1 % |
| 2028 onwards | 30 % | 1 % |
Default values do not need verification and can be used for all imports in 2026 and later. When default values are used, the free allocation adjustment uses the default benchmark (column B of 2025/2620) for the production route indicated for that country.
Actual values
Actual embedded emissions are calculated by the installation operator under the methodology in Implementing Regulation (EU) 2025/2547, covering the production process and its precursors. They must be verified by a verifier accredited under CBAM, which includes site visits. Operators can register their installations in the CBAM Registry and share verified data with all their EU customers. The first verification reports for 2026 production can be issued from January 2027.
What the difference is worth: an example
1,000 tonnes of hot-rolled flat steel (CN 7208 10 00) from China, imported in 2026, at the 2026 Q3 price of €82.32:
| tCO₂e/t | Certificates | Cost | |
|---|---|---|---|
| Default value 2026 (total 3.187 + 10 %) | 3.506 | 2,170 | €178,655 |
| Verified actual value (example) | 2.000 | 664 | €54,681 |
| Default value 2028 (+30 %, CBAM factor 90 %) | 4.143 | 2,910 | €239,551 |
Benchmark (route C, BF/BOF): 1.370 tCO₂e/t × 97.5 % in 2026. Same price assumed for 2028. The actual-value line is a simplified illustration: with actual data the column A benchmark and the precursors’ free allocation apply.
Because the free allocation adjustment removes almost all benchmark-level emissions in 2026, the certificates you pay for are mostly the gap between your product’s emissions and the benchmark. A cleaner supplier, or simply real data instead of a marked-up default, changes that gap a lot.
Which should you use?
| Situation | Recommendation |
|---|---|
| Few tonnes, many suppliers | Default values are usually enough in 2026, while the mark-up is still 10 %. |
| Large volumes from a few mills | Ask the producer for verified actual data. Verification pays for itself quickly, and the gap widens as the mark-up rises to 30 %. |
| Scrap-based EAF or low-carbon power | Actual data is likely far below the country default. |
| New or renewed supply contracts | Include the obligation to deliver verified data, and the cost consequence if it is missing. |
Compare scenarios in the CBAM cost calculator (switch “Embedded emissions” to the supplier’s actual value).