CBAM

Default values or actual data: the CBAM choice an exporter can still influence

Under CBAM your customer can declare your goods on a table figure or on your own verified data. Which route applies depends on what you can supply, and when.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 22 October 2026 · Sources last checked 22 October 2026

Two routes to the same declaration

Each year the importer, the authorised CBAM declarant, reports the embedded emissions of the goods it brought into the EU. It can do so in one of two ways: on EU default values, or on the actual emissions of the installation that made the goods. The choice is the importer’s, but only you can supply the second kind of data.

What default values are

Default values are figures published by the European Commission for each covered product. They are set in Commission Implementing Regulation (EU) 2025/2621, which was corrected in July 2026 by Implementing Regulation (EU) 2026/1740, and the Commission publishes them in a spreadsheet for information.

They are built as a fallback, not as a fair reflection of any one producer. They include a mark-up that rises over the first years of the definitive regime, and the rate depends on the sector, so read it in the regulation before you quote a figure to a customer. The consequence is simple: if your real emissions are well below the default, declaring on the default means your customer pays for emissions you did not produce.

What actual data requires

Actual emissions must be verified by an independent verifier accredited by an EU or EEA national accreditation body, and verification takes place at the level of the installation. A verifier checks your records and your method, so both have to exist before the verifier arrives.

• The boundaries of the installation and the production processes that make the goods.
• Records of fuel use, electricity use and the quantities produced.
• Data from your own suppliers for the materials you buy in.
• A written monitoring plan and a calculation method that a verifier can follow.
• A person in the company who owns the data and answers the verifier’s questions.

The two routes side by side

How to decide

1. Find the default figure for your product in the Commission’s table, and note the mark-up for your sector.
2. Make a rough estimate of your own emissions per tonne from your fuel, electricity and production records.
3. If your estimate is clearly below the default, verified data is probably worth pursuing. If it is close to or above it, it may not change your customer’s bill.
4. Ask each EU customer which route they plan to use and what they need from you, and by when.
5. Start early. Collecting records, writing the plan and finding a verifier all take time, and the first declaration covers 2026 imports.

The free CBAM Compass Report gives you a first view of where you stand on these checks and the cost per tonne your buyers may face on default values, in about three minutes.