CBAM default values and the markup
When you can't prove a supplier's actual emissions, CBAM bills you at the default — set high on purpose. Here's why proving actuals lowers both the bill and the recorded carbon.
Last updated 29 June 2026
The single number that decides a CBAM line is its embedded emissions — the tonnes of CO₂e behind the goods. Where that number comes from is the difference between a fair bill and an avoidable markup.
Two ways to get the number
For every line, CBAM allows two sources for the embedded emissions:
- Actual values — calculated from the producing installation’s real data, covering the direct emissions of production and the indirect emissions of the electricity used.
- Default values — a fallback the EU publishes for each good and route, applied when actual data isn’t available.
The catch is that default values are set high — built on a conservative, dirty-production assumption. That’s deliberate: the default is meant to be worse than reality, so that proving the actual is always worth the effort.
Where the markup comes from
If you buy from a cleaner-than-average producer but can only show the default, CBAM charges you as though you bought from a dirty one. The certificate cost is calculated on emissions the goods never produced, and the carbon recorded against your import is inflated.
Proving the supplier’s actual emissions closes that gap. Both the bill (in €) and the recorded carbon (in tCO₂e) fall to the real figure — and the cleaner producer you chose finally counts in your favour.
Direct and indirect, per tonne
Embedded emissions are expressed as an intensity — tCO₂e per tonne of goods — split into:
- Direct: the production process itself (the furnace, the kiln, the reduction).
- Indirect: the electricity consumed in production, for the goods CBAM includes it for.
Multiply the intensity by the net mass on your customs declaration and you have the embedded total for the line. The certificate cost is that total times the certificate price, which tracks the EU ETS.
The data-quality ladder
Not all “actual” data is equal, and the tier decides what you can rely on:
- EU default — the high fallback. Pay it when nothing better is on the line.
- Self-reported actual — the supplier’s declared figure for their installation. Lower and specific; the moment cleaner production starts to count.
- Verified actual — the actual, confirmed by an accredited verifier’s report. This is what the definitive period ultimately bills on.
The climb from default toward verified is exactly where money and carbon come down. A platform’s job is to make where each line sits legible — and to carry the supporting data so the figure is provable, not just asserted.
Default values, surrender ratios and verification requirements are set by EU rules that continue to evolve. Confirm the current figures and verification standards against official guidance before relying on them.
Next: put real numbers behind this with the free CBAM calculator, or read what CBAM is.