Glossary
Actual emissions – CBAM
Under the EU's Carbon Border Adjustment Mechanism (CBAM), emissions calculated from primary data from the production processes of goods and from producing the electricity those processes consume. They are the alternative to default values.
- Legal source
- CBAM Regulation, Article 3(28) ↗
- Who it applies to
- Authorised CBAM declarants that determine the embedded emissions of their imports on the basis of actual emissions: they must have them verified by an accredited verifier, or use verified information a registered producer outside the EU discloses to them. Registered operators of installations outside the EU determine the embedded emissions of their goods and have them verified.
- Example
- For threaded steel bolts from China, Combined Nomenclature (CN) code 7318 15, the default value is 6.375 tonnes of CO₂ equivalent (CO₂e) per tonne, or 7.0125 tonnes with the 10% mark-up for 2026. If the producer determines its own embedded emissions and has them verified, the authorised CBAM declarant importing the bolts can declare those actual emissions instead.
- Also known as
- actual embedded emissions, CBAM actual emissions
The CBAM Regulation (Regulation (EU) 2023/956) defines actual emissions as the emissions calculated based on primary data from the production processes of goods and from the production of electricity consumed during those processes, as determined by the methods in its Annex IV.
Where embedded emissions are determined on the basis of actual emissions, the authorised CBAM declarant must have the total in its CBAM declaration verified by an accredited verifier, a
Pending, not law: Commission proposal COM(2025) 989 of 17 December 2025 would refer to embedded emissions "determined on the basis of actual emissions provided by the operator via the CBAM registry". Our reading: declarants could then use actual emissions only where the producer provides them through the registry.
Our explainer on default values and actual emissions helps you choose between the two.
Regulations
Carbon Border Adjustment Mechanism (CBAM)
Implementing Regulation (EU) 2026/1740 corrected Annexes I and IV of the default values act, Implementing Regulation (EU) 2025/2621
Used in
EU CBAM default values or actual emissions: which to use, and how embedded emissions are calculated
Under the EU CBAM, you declare embedded emissions from verified supplier data or from default values with a mark-up. How to choose, and what to ask suppliers.