CBAM default values vs actual emissions: which should your buyer use?
Your buyer can declare your goods using your actual emissions or the EU's default values. The choice affects their cost, and whether they keep buying from you.
Quick answer
Default values are the EU's standard emission figures by product and country, with a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. Actual emissions are usually lower but can only be used once verified by an accredited verifier. Suppliers below the default usually gain from verifying.
What default values are
Default values are the EU's standard emission figures for each CBAM product, by country of origin. The importer uses them when it has no usable actual data from the supplier. For the definitive period they were set in Implementing Regulation (EU) 2025/2621, and a limited number were corrected by Implementing Regulation (EU) 2026/1740. The current values are published by the Commission as a downloadable spreadsheet.
Default values include a deliberate mark-up for most sectors, including aluminium and steel: 10% in 2026, rising to 20% in 2027 and 30% from 2028. The mark-up exists to reward suppliers who provide real data.
What actual emissions require
To use your actual emissions, the importer needs data calculated with the EU methodology and verified by an accredited verifier. For the first reporting period, each installation needs a physical site visit. If verification doesn't happen or fails, default values apply.
Verification takes planning. Verifiers need access to your monitoring records, and capacity is limited while the market builds up. Book early if you plan to verify 2026 data.
How to decide
| Situation | Usually the better choice |
|---|---|
| Large EU volumes, one or more major buyers | Actual, verified data |
| You use a lot of scrap or low-emission metal | Actual data; the default won't reflect it |
| Your metal supplier can't give you its data | Actual data for your own process, default value for the precursor |
| Very small or one-off EU shipments | Default values may be acceptable; ask the buyer |
| Buyer imports under 50 tonnes a year in total | The buyer may be exempt; confirm first |
The cost your buyer sees
The importer's cost is roughly the embedded emissions it declares, multiplied by the CBAM certificate price and reduced by the share still covered by EU free allocation, which is being phased out over the coming years. So every tonne of CO2 you shave off your declared figure lowers your buyer's cost, and the gap grows each year as the mark-up rises and free allocation falls.
A practical route for most suppliers
- Calculate your actual emissions with the EU method now, even before verification. You'll know whether you're above or below the default.
- Share the calculation with your main buyers so they can plan.
- If you're clearly below the default, book verification for your 2026 data.
- Push your metal suppliers for their own data at the same time.
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Send your requestFrequently asked questions
What is the default value mark-up under CBAM?
For most sectors including aluminium and steel, default values carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028.
Can my buyer use my emissions data without verification?
Not for the definitive declaration. Actual emissions must be verified by an accredited verifier; otherwise default values apply.
Where are the default values published?
The European Commission publishes the current CBAM default values as a spreadsheet on its CBAM pages. They were set by Implementing Regulation (EU) 2025/2621 and partly corrected by Implementing Regulation (EU) 2026/1740.
Sources
- European Commission: CBAM communication and news (guidance, templates, default values)
- European Commission: CBAM definitive regime
- German Emissions Trading Authority (DEHSt): CBAM definitive regime from 2026
This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.