Leaked provisional CBAM values: Cost burden rises significantly due to higher default values

New benchmarks and default values leaked

In the final weeks of the year, the European Commission is defining key elements for CBAM through the remaining implementing acts. Among these are the legal acts for calculating default values and CBAM benchmarks. These will form the basis for CBAM cost calculations once the regulatory phase begins in January 2026. Although officially recognised, the CBAM benchmarks are still considered provisional and will likely be adjusted as the EU Emissions Trading System and its benchmarks are updated. According to information from McCloskey, the implementing acts confirm three permitted methods for determining emissions: the use of actual values, the application of default values, or a mixed methodology. The latter appears to be a consequence of insights gained during the transitional phase, in which reporting companies struggled to obtain emissions data across entire supply chains. The previously applicable 80/20 rule proved hardly practical. Companies will now likely be allowed to use default values for certain precursor products while using actual values for other production steps or precursors. Due to the complexity of data collection and the challenges associated with verification, many importers will likely be forced to rely on default values. This can have significant financial consequences.

Significant adjustments to benchmarks and default values

Of particular note are substantial reductions in benchmark values for several CN codes. In some cases, values have been cut by more than 40 percent. This measure appears intended to protect European industries, especially in the steel and semi-finished products sectors. For importers, however, this represents a shock, as it results in drastic cost increases. At the same time, default emissions values for key countries of origin have been raised. For example, a current shipment of hot-rolled coil from India could incur CBAM costs of up to 270 euros per tonne when default values are applied. For stainless steel products, reliance on default values can also have a major impact: around 710 euros per tonne from Indonesia, 500 euros from India and 420 euros from China. Indonesia in particular stands out with extremely high values. More generally, the leaked default values have increased considerably compared to those previously derived from the Commission’s JRC report. An example is South Korea under CN code 72193510: until now, the direct emissions value was 1.82 tCO₂/t; it is now expected to be 3.65 tCO₂/t. These values do not yet include the proportional surcharge.

Tiered surcharges and standardised production routes

The European Commission has decided on a phased introduction of surcharges on default values. For most goods, these begin at 10 percent in 2026, rise to 20 percent in 2027, and reach 30 percent from 2028 onward. The fertiliser industry has secured an exemption (likely through intensive lobbying): for this sector, the surcharge will remain limited to 1 percent until 2029. In addition, each country of origin has now been assigned a fixed production route, which will serve as the basis for calculating CBAM costs. This measure aims to improve comparability and prevent countries from being mistakenly classified as less emissions-intensive. This is especially important for the production-route-specific CBAM benchmarks.

Impact of missing origin data

Compared to earlier drafts, certain combinations of CN codes and countries of origin have been removed from the country-specific tables. These products will now fall under the category “Other countries and territories.” This will lead to a higher emissions assessment and accordingly increased CBAM costs, since the value for this fallback category corresponds to that of the 10 worst-performing countries. The values applicable for 2026 are officially classified as “provisional benchmarks.” They remain valid until new ETS benchmarks are published next year. From 2027 onward, updated CBAM values based on the new data will apply.

Verification capability remains an uncertainty factor

Although CBAM allows the use of actual emissions data, it is already becoming clear that many verifiers and production sites are not yet adequately prepared. Challenges include site access, accreditation and dealing with third countries that are sceptical of external verification. Some manufacturers possess environmental product declarations, but these are not automatically CBAM-compliant. At best, they demonstrate that emissions data exists; however, they do not meet the stringent requirements for traceability and methodological robustness under the CBAM regulation. If current verification issues persist, many importers may be forced to rely on costly default values. To avoid this, companies should begin optimising their data processes now and intensify communication with suppliers. Above all, companies must urgently calculate their costs based on the new values-especially for goods that may already be en route to Europe.

Support with strategic preparation

If you are affected by these developments and need help calculating your CBAM costs or understanding the new documents, feel free to contact me directly at helge@kolum.earth. We are happy to support you.