Emission data & default values
The size of the CBAM burden hangs on the embedded emissions of your goods. Where real values from the producer exist, you calculate with them. Where they are missing, default values apply, and those are deliberately expensive.
- Without real data, conservative default values apply.
- Default values carry mark-ups that rise over the years by design.
- Data collection along the supply chain is often the biggest cost lever.
Real values against default values
Embedded emissions can be set in two ways: with the actual, evidenced values of the producer or, where those are missing, with default values. The default values are country- and product-specific and deliberately conservative. They exist so that missing data does not lead to an under-valuation. For importers that means default values are almost always the more expensive option.
The mark-ups rise
The conservative mark-ups on default values are not static. They are designed to climb over the years. What looks bearable in 2026 turns dearer in 2027 and from 2028. The incentive to switch to real data grows year on year. Obtain data early and you secure the better basis for good.
How collection works
Real values come from the producer, sometimes across several stages of the supply chain. That calls for a structured request, clear questions and patience. The responses must be sense-checked and prepared. This is exactly where many fail: the request fizzles out, the supplier does not answer, the deadline closes in, and in the end the authority calculates on default values. Clean supplier communication is no side matter.
Written and maintained by the EnergyFlow Regulatory Desk, the CBAM-focused division of EnergyFlow GmbH. As of June 2026. Legal basis: Regulation (EU) 2023/956, amended by the Omnibus Regulation (EU) 2025/2083 (Official Journal of the EU, 17 October 2025). Primary sources: EUR-Lex and the official CBAM page of the European Commission.
Information on the CBAM is given to the best of our knowledge, as of June 2026, without guarantee. Dynamic values such as certificate prices, default values and deadlines can change. The applicable legal acts and the competent authorities are decisive. This article is not legal, tax or customs advice.
What does this mean for your imports?
General explanations are a start. The CBAM Decision File examines your specific case in seven working days.