CBAM default values vs actual data: mark-ups and when to switch
CBAM default values are emission intensities set by the European Commission for each CBAM good and country of origin, which an EU importer uses when it has no verified actual emissions data from the producing installation. In the definitive period they include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). Actual emissions data needs verification, but for most efficient producers it leads to fewer CBAM certificates.
Where CBAM default values come from
The legally binding default values for the definitive period are in Commission Implementing Regulation (EU) 2025/2621, adopted in December 2025 and applying from 1 January 2026. Its Annexes I and IV were replaced in full by a correcting act, Implementing Regulation (EU) 2026/1740, published on 31 July 2026 and applying back to 1 January 2026. The Commission also publishes the values in a spreadsheet for information; the regulation is what counts.
The regulation contains several sets of values:
- Values by country of origin and CN code for cement, iron and steel, aluminium, fertilisers and hydrogen, covering direct emissions and, where relevant, indirect emissions and totals.
- Fallback values for "other countries and territories", used where no country-specific value is set.
- Precursor values used where the country of production of a precursor cannot be identified.
- Values for electricity and for the indirect emission factor of electricity consumed.
Where the data for a country was not judged reliable, the defaults are based on the average emission intensity of the ten exporting countries with the highest intensities for that good. Defaults are meant to be conservative. The regulation provides for them to be revised by the end of 2027 at the latest.
The corrections made in July 2026 apply retroactively, so any 2026 calculation built on the December 2025 annexes should be re-run.
The CBAM mark-up, year by year
The mark-up is added on top of the default value. It reflects the fact that some installations emit more than their country average, and it rises so that importers have a growing reason to obtain actual data.
| Year of import | Cement, iron and steel, aluminium, hydrogen | Fertilisers | Electricity |
|---|---|---|---|
| 2026 | +10% | +1% | No mark-up |
| 2027 | +20% | +1% | No mark-up |
| 2028 onwards | +30% | +1% | No mark-up |
The Commission set the lower fertiliser rate in view of that sector's specific circumstances. The CBAM Registry applies the mark-up to the base default value; declarants do not add it by hand.
CBAM default values vs actual emissions: the comparison
| Default values | Actual emissions | |
|---|---|---|
| Source | Commission regulation, by product and country | Installation's own monitoring under the CBAM methodology |
| Mark-up | Yes, rising to 30% (1% for fertilisers) | None |
| Verification | Not needed | Required, by an accredited verifier |
| Effort for the producer | None | Monitoring plan, calendar-year data, evidence, verification |
| Carbon price paid deduction | Limited — Commission default carbon prices may apply where published | Carbon price effectively paid, with verified evidence |
| Typical outcome for an efficient producer | Higher embedded emissions | Lower embedded emissions |
A worked illustration
The figures here are illustrative, not real default values. Suppose the base default for a steel product from a given country is 2.00 tCO2e per tonne and a verified actual value from one installation is 1.40. For 1,000 tonnes imported:
- 2026: default 2.20 × 1,000 = 2,200 tCO2e vs actual 1,400 tCO2e — a gap of 800 tCO2e.
- 2027: default 2.40 → gap of 1,000 tCO2e.
- 2028: default 2.60 → gap of 1,200 tCO2e.
Each tonne of gap is a certificate the importer would otherwise buy, before the free allocation adjustment. The reverse also holds: an installation that emits more than the default may find defaults cheaper for its customers, though the mark-up narrows that advantage each year.
How to find the right default value
- Confirm the CN code of the good as declared at customs. Default values are set at CN code level, and neighbouring codes can carry different values.
- Confirm the country of origin. Use the country-specific row where one exists; otherwise the "other countries and territories" value applies.
- Use the corrected annexes. Work from Implementing Regulation (EU) 2025/2621 as corrected by Implementing Regulation (EU) 2026/1740, not from earlier spreadsheets or the transitional-period values.
- Pick the right component. For steel, aluminium and hydrogen, the certificate obligation uses direct emissions; for cement and fertilisers, direct and indirect.
- Apply the mark-up for the year of import, or let the CBAM Registry do it.
- Record the version used, so a later correction can be traced and recalculated.
Producers can run the same exercise for their own products to see what their customers would face without actual data. That number is a useful anchor in commercial discussions.
Precursors: mixing actual and default values
A producer can report actual values for its own processes while using default values for purchased precursors. The precursor default then carries the mark-up for the relevant year. Precursor actual values can only be used if backed by a verification report covering the period in which the precursor was produced. For many producers, precursors are where most of the remaining exposure sits; our guide to calculating CBAM embedded emissions shows how they flow through.
When to use CBAM actual emissions — and when defaults are fine
- Large, recurring volumes from the same installation: actual data almost always pays back the cost of monitoring and verification.
- Efficient production routes — scrap-based EAF steel, secondary aluminium, low-carbon fuels: the gap to defaults is likely to be large.
- Small or occasional shipments, or traders buying from many mills: defaults may be the practical choice, at least for 2026.
- Installations above the default: check before investing in verification, but plan for the rising mark-up.
Once an importer has verified data for an installation, it should use it consistently unless there is a documented gap. For exporters, the commercial point is in our guide for Indian steel and aluminium exporters.
Default values, the correcting act and the methodology may change again. Check the latest Commission regulation and guidance before relying on any specific value.
How EKOTRACE helps
EKOTRACE stores default values as versioned reference data and calculates actual specific embedded emissions for each installation, process and precursor, so producers and importers can see actual against default side by side for 2026, 2027 and 2028. When a correcting act changes the defaults, recalculations run against the new version while earlier results remain traceable.
See our CBAM compliance page, how importers collect installation data through the supplier portal, or the CBAM definitive period overview.
Frequently asked questions
What is the CBAM mark-up?
It is a percentage added to the Commission's default values in the definitive period: 10% for imports in 2026, 20% in 2027 and 30% from 2028. Fertilisers have a 1% mark-up and electricity none. It does not apply to verified actual values.
Can importers keep using CBAM default values?
Yes. Default values are a lawful option where verified actual data is not available. They are designed to be conservative and become more expensive each year as the mark-up rises.
Which regulation sets the CBAM default values?
Commission Implementing Regulation (EU) 2025/2621, as corrected by Implementing Regulation (EU) 2026/1740, which replaced its Annexes I and IV with effect from 1 January 2026. The Commission's spreadsheet is for information only.
Do default values need verification?
No. Only actual emissions data must be verified by an accredited verifier before an importer can use it in a CBAM declaration.