CBAM Default Values vs Actual Emissions: When Verified Data Pays Off

Updated 2026-10-11.

In 2026, an EU importer can declare CBAM goods using EU default values or the producer's verified actual emissions. Default values come from Implementing Regulation (EU) 2025/2621 and carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). If your real intensity is near or below the default, verified data almost always pays.

At a glance

	Default values	Verified actual emissions
Legal source	Implementing Regulation (EU) 2025/2621, corrected by 2026/1740	Producer data under the CBAM methodology
Verification needed	No	Yes, by an accredited verifier
Mark-up	10% (2026), 20% (2027), 30% (2028 on); fertilisers 1%	None
Best for	Producers with high intensity or no data yet	Producers at or below the default
Review	Default values must be revised by December 2027	Annually, with each reporting period

The decision in one formula

Choose verified data when: (default value × (1 + mark-up) − your actual intensity) × tonnes × certificate price > the cost of measuring and verifying.

Worked example

A supplier ships 1,000 tonnes of steel a year. The default value for its product is 2.1 tCO2 per tonne; its verified intensity is 1.9.

Year	Default with mark-up	Actual	Tonnes of CO2 avoided	Value at €82.32
2026	2.31	1.9	410	≈ €33,800
2027	2.52	1.9	620	≈ €51,000
2028	2.73	1.9	830	≈ €68,300

Even a supplier slightly above the default can benefit once the mark-up reaches 30%. Check your own case in the CBAM cost calculator.

When defaults can make sense

Your real intensity is well above the default, so verified data would raise the cost.
Volumes are small and the buyer stays under the 50-tonne annual threshold.
You cannot collect installation data before the buyer's declaration deadline (30 September 2027 for 2026 imports).

What verification involves

Monitoring: fuel, power, raw materials and output per installation for the reporting period.
Calculation under the CBAM methodology, including relevant precursors.
A visit or desk review by a verifier accredited under the CBAM rules. The Commission expected the first accreditations around September 2026, with verification work from early 2027.

Frequently asked questions

Did default values disappear in 2026?

No. Default values remain available in the definitive period, but with a rising mark-up. They are due for revision by December 2027.

Does my buyer choose, or do I?

The importer declares, but it can only use actual values if you supply them, verified. Agree this in the supply contract.

Do fertilisers get the same mark-up?

No. Fertilisers carry a 1% mark-up from 2026, so the incentive to switch comes mainly from a lower actual intensity, not from the mark-up.

Can I use actual data for some products and defaults for others?

Yes, the choice is made per good and installation, as long as the data meets the methodology.