Explainer12 min read

EU CBAM default values or actual emissions: which to use, and how embedded emissions are calculated

By Clara Christ and Cenker KaragözPublished 21 Oct 2026Status as of 21 Oct 2026

Who it applies to: Authorised CBAM declarants that import CBAM goods other than electricity, and the producers outside the EU whose installations make those goods.
What to do: Choose verified actual emissions from your supplier or the Commission's default values with their mark-up, and ask your suppliers for their data now. Our reading: you can choose differently for each type of goods.
Deadline: By 30 September each year for the year before; the first time in 2027, for 2026, with any verification reports.
Legal basis: CBAM Regulation, Article 7, Article 8 and Annex IV; Implementing Regulation (EU) 2025/2547 on calculation methods; Implementing Regulation (EU) 2025/2621 on default values, as corrected by Implementing Regulation (EU) 2026/1740; Implementing Regulation (EU) 2025/2546 on verification

Part of CBAMIn forceChange pendingdefinitive period since 1 January 2026

Under the Carbon Border Adjustment Mechanism (CBAM), you declare the embedded emissions of the goods you import in one of two ways: actual emissions, worked out from your supplier's installation data and checked by an accredited verifier, or default values set by the Commission 1 3. Default values need nothing from your supplier, but they carry a mark-up, which for cement, iron and steel, aluminium and hydrogen rises each year until 2028 4. Actual emissions reflect your supplier's own installation, and they count only if your supplier works them out under the EU's calculation rules and a verifier checks the result 3 8 12. Your first declaration covers the goods you imported in 2026 and is due in 2027, by 30 September 6. The rules are in the CBAM Regulation (Regulation (EU) 2023/956); our CBAM hub explains the mechanism as a whole.

What are embedded emissions, and why do they set what I pay?

Embedded emissions are the greenhouse gases released in making your goods, counted in tonnes of CO₂ equivalent (CO₂e), which puts every greenhouse gas on the scale of CO₂ 12. In law they cover direct emissions from production and indirect emissions from the electricity used in it 12. For most iron and steel goods, aluminium, hydrogen and electricity, only direct emissions count 1 13. Goods not on that list, cement and fertilisers among them, count indirect emissions as well 1 4 13.

They decide how many certificates you surrender. One CBAM certificate covers one tonne of CO₂e, and your declaration turns the embedded emissions of your goods into a number of certificates 6 12. That number is reduced for a carbon price paid outside the EU and adjusted for the free allowances EU producers get under the EU Emissions Trading System (EU ETS) 6. Our explainer on CBAM certificates covers both steps and the price.

Should I use default values or actual emissions?

Use actual emissions only where your supplier can give you verified data for the goods; otherwise you use default values 1 3. Our reading: you can choose differently for each type of goods, because the records you must keep note actual emissions or default values for each type of goods you import 5. Four questions settle it for each good.

Is the good electricity? If yes, default values apply unless you meet strict conditions, among them a power purchase agreement and a power plant that emits no more than 550 grammes of CO₂ of fossil fuel origin per kilowatt-hour 1 7. The rest of this page is about other goods.
Can your supplier give you embedded emissions calculated under the EU rules and checked by an accredited verifier? If no, use default values. Actual emissions in your declaration must be verified by an accredited verifier 3 6.
Would the verified figure come out below the default value with its mark-up? If yes, actual emissions give you fewer tonnes of CO₂e to declare; if not, default values give you fewer, but check question 4 before you decide 4 6. Our reading: the comparison is per tonne of goods, between your supplier's verified figure and the default value plus mark-up, and the mark-up grows until 2028 4.
Did your supplier pay a carbon price where the goods were made? The certificates you surrender are your embedded emissions after a reduction for a carbon price paid outside the EU, so the method also changes what you can deduct 6. With actual emissions, you can deduct the carbon price effectively paid, backed by documentation certified by an independent person 14. With default values, you can deduct it only by reference to yearly default carbon prices, which the Commission may determine and make available in the CBAM Registry from 2027 14. Our reading: where your supplier paid a carbon price, actual emissions can mean fewer certificates even when the verified figure is above the default value with its mark-up 6 14.

The result: if you answered no to question 2, plan on default values and keep the records of what you imported 3 5. If you answered yes, weigh questions 3 and 4 together: the tonnes of CO₂e each method gives you, and the carbon price each lets you deduct 6 14. Where actual emissions come out ahead, ask your supplier for verified data now; where default values do, plan on them and keep the same records 3 5. A middle way exists for goods made from other CBAM goods, called precursors: the producer can use actual emissions for its own production and default values for one or more precursors 15.

How do default values work?

A default value is the Commission's figure for the embedded emissions in one tonne of a good, set for each country the good is exported from 7. It is the average emission intensity of that country for that good, increased by a mark-up 7. When reliable data for a country can't be used, the default value is the average of the 10 exporting countries with the highest emission intensities for that good 7.

The binding values are in Annex I to Implementing Regulation (EU) 2025/2621 9. Implementing Regulation (EU) 2026/1740 replaced that annex with corrected tables, applying from 1 January 2026 10 16. Commission guidance, not law: the Commission's Excel file of default values is for information only, and the legally binding values are the ones in the regulation 17.

To read the table, you take the value in the "total emissions" column for your good and its country 4. If the country isn't listed, or shows no value, you take the value from the table "Other countries and territories" 4. Then the mark-up is added: for cement, iron and steel, aluminium and hydrogen, 10% for 2026, 20% for 2027 and 30% for 2028 onwards; for fertilisers, 1% from 2026 4. The CBAM Registry, the system you submit your declaration in, calculates the final values with the mark-up 6 18.

The same act has separate default values for indirect emissions, for electricity and for precursors whose country of production is unknown 9. The values can change: the act is to be revised in 2027 at the latest, and the Commission must review the default values by December 2027 19 20.

Example: steel bolts from China

Example. The company and the quantity are made up to show how the rules work; the default value and the mark-up are official 34. An authorised CBAM declarant imports 30 tonnes of carbon-steel screws and bolts (Combined Nomenclature (CN) code 7318 15) made in China, in August 2026, and its supplier has no verified data 11 34. Its other CBAM imports take its 2026 total above 50 tonnes, so the 50-tonne threshold doesn't exempt it 21 22 34. Our threshold explainer walks through that test.

The default value for these goods from China is 6.375 tonnes of CO₂e per tonne 4. They are iron and steel goods, so only direct emissions count 1 13.
Without the mark-up, the 30 tonnes carry 191.25 tonnes of CO₂e 34.
With the 10% mark-up for 2026, the value becomes 7.0125 tonnes per tonne, or 210.375 tonnes of CO₂e for the shipment 4 34. The mark-up alone adds 19.125 tonnes 34.
The same value would rise to 7.65 tonnes per tonne in 2027, and to 8.2875 tonnes per tonne from 2028 4 34.

Our reading: verified actual emissions below 7.0125 tonnes of CO₂e per tonne of bolts would cut the 2026 figure, and each tonne less per tonne of bolts means 30 tonnes of CO₂e less on this shipment 34. These are our illustrations: the CBAM Registry does the final calculation, and our sources don't say how it rounds 18 34. What the tonnes cost in certificates is in our certificates explainer.

How are actual emissions worked out?

Actual emissions come from the producer, not from you: the operator of the installation outside the EU monitors its production and works out the embedded emissions of each type of goods 2 12 23. The method is in Annex IV to the CBAM Regulation, set out in detail in Implementing Regulation (EU) 2025/2547 1 8.

For a simple good, made only from inputs and fuels with no embedded emissions, the specific embedded emissions are the emissions attributed to its production process, per tonne of the good produced at the installation in the reporting period 7. For a complex good, the embedded emissions of the CBAM goods used to make it are added 7. The installation counts only the processes inside the system boundaries, which cover direct emissions, indirect emissions for goods outside Annex II and the embedded emissions of any precursor 24.

The reporting period for goods imported in 2026 is the year 2026 25. For goods imported in other years, it is by default the calendar year of import, or the period of production where there is enough evidence of when the goods were made 25.

The operator writes an operator's emissions report, in English, and a summary of it, and sends them to its verifier 23. It uses the CBAM Registry if it is registered there, and other means if it isn't 23.

Who verifies actual emissions, and when?

If you declare actual emissions, you must make sure a verifier accredited under the CBAM Regulation has verified the total embedded emissions in your declaration 3. If your supplier's installation is registered in the CBAM Registry, you can meet that duty with the verified information the operator discloses to you 2 3.

The verifier must find with reasonable assurance that the report is free of material misstatements and material non-conformities 26. In plain words: the verifier checks for errors in the reported data (misstatements) and for breaches of the calculation rules in Annex IV (non-conformities) 11 26. Reasonable assurance is the level of confidence it must reach, which the rules on site visits link to cutting the verification risk to an acceptable level 26 27. Material means big enough to count, and the materiality level is the threshold the verifier uses to decide that 26. For each tonne of a good, identified by its CN code, that level is 5% of the total specific embedded emissions; below it, the verifier can still judge an error material from its size and nature 11.

The verifier normally visits the installation 26. It can replace the physical visit with a virtual one, or waive it, where a set of conditions is met, including a physical site visit during the reporting period immediately before 27 28. It can also switch to a virtual visit when serious, extraordinary and unforeseeable circumstances outside the operator's control prevent a physical one 28 29. Our reading: an installation that had no physical site visit by a verifier in the previous reporting period can't use the first set of conditions, so it needs a physical visit unless such circumstances prevent one 27 29.

Accredited verifiers can register in the CBAM Registry from 1 September 2026 30. Commission guidance, not law: the Commission's verification page says the first CBAM verifiers are expected to receive accreditation around September 2026 31. Its timeline for 2027 starts in January, when accredited verifiers can issue the first verification reports 31. The list of accredited verifiers will be published on that page 31. Your declaration includes copies of the verification reports, and you keep them with your records 1 6. The verifier's side and the operator's registration are in our explainer for producers and exporters outside the EU.

What should I ask my supplier for?

Ask for the data the operator's summary emissions report contains, and for what you must keep on record 5 32. Ask early: your supplier needs a verifier, and the verification report goes with your declaration 3 6.

Model wording for a request to a supplier outside the EU. Replace the parts in curly brackets.

Subject: CBAM emissions data for {product, CN code}, reporting period 2026
We import {product, CN code} produced at your installation {name, address}. Under the EU Carbon Border Adjustment Mechanism (CBAM), we must declare the embedded emissions of these goods in our CBAM declaration for 2026 .
Please tell us by {date} whether you will provide actual embedded emissions for these goods, calculated under Implementing Regulation (EU) 2025/2547 and verified by a CBAM-accredited verifier .
If you will, please send us: the name of the operator and of the installation, the installation's unique identifier in the CBAM Registry, its full address in English and the geographical coordinates of its main emission source ; the operator's contact information ; for each good we buy, by CN code, the specific direct embedded emissions and the share of embedded emissions for which default values were used ; {for goods such as cement or fertilisers: the specific indirect emissions} ; information on the method used to calculate the embedded emissions ; and the verification report, or, if your installation is registered in the CBAM Registry, confirmation that you will share the verified information with us there .
{If you paid a carbon price on these emissions: the amount, the documentation certified by an independent person, and evidence of payment.}
If you can't provide verified data, please tell us, so that we can declare default values .

When default values apply instead: if the supplier says no, or can't have its data verified in time, you declare default values for those goods 1 3. Whichever you use, you keep the type and quantity of each type of goods, the country of origin and whether you used actual emissions or default values 5. For actual emissions, you also keep the installation's identification, the operator's contact details, the verification reports, the specific embedded emissions and the calculation method 5.

This is general information, not legal advice. For decisions about your company, check with a lawyer or adviser.

What might change?

Pending, not law: Commission proposal COM(2025) 989 would change parts of these rules 33. Producers would have to register in the CBAM Registry for their actual emissions to be used, and declarants could have to show evidence of where and when the goods were produced 33. Artificially adjusting supply chains to benefit from lower default values would count as circumvention 33. Default values for imported electricity would be recalculated to take account of electricity from all sources 33. Our Decode on the downstream proposal follows it.

What to do

List the CBAM goods you import, by type of goods and country of origin; you must keep those records whichever method you use 5.
For each good, look up the default value for its country in Annex I to Implementing Regulation (EU) 2025/2621 and add the mark-up, so you know the figure verified data would have to beat 4.
Ask each supplier whether it will provide verified actual emissions, using the model wording above 3 23.

If yes, agree how you receive the verified data: through the CBAM Registry if its installation is registered, or with the verification report 2 3.
If no, plan on default values for that good 1.

If your supplier paid a carbon price, collect the certified documentation and evidence of payment; with default values, only yearly default carbon prices count 14.
Submit your CBAM declaration by 30 September each year for the year before, the first time in 2027 for 2026, with copies of any verification reports 6.
Keep the records, including the verifier's report, until the end of the fourth year after the year of the declaration 1.