Default values corrected retroactively: what Regulation 2026/1740 changes and where verification stands

The Commission makes corrections

On 31 July 2026, the Commission published Implementing Regulation (EU) 2026/1740 in the Official Journal. It corrects Annexes I and IV of the default values regulation, Implementing Regulation (EU) 2025/2621, entered into force on 3 August 2026 and applies retroactively from 1 January 2026. It affects every authorised CBAM declarant that determines the embedded emissions of its imports, in whole or for precursors, on the basis of default values. Most of the corrections fix transcription errors from the consolidation of the tables in December.

Transcription errors with price effects

The correction has its greatest practical effect for Taiwan. The December version contained dedicated country values for stainless steel under CN codes 7218 to 7223 of between 8.63 and 10 tonnes of CO2e per tonne of goods, which were based on transcription errors. These values are deleted without replacement, so the fallback table for other countries and territories now applies to Taiwan. Its values for the same goods range from around 4.8 to 5.0 tonnes. For imports of stainless steel from Taiwan, the applicable default values therefore roughly halve, retroactively from 1 January 2026. Anyone who calculated on the basis of the old tables can adjust their provisions downwards accordingly.

Not every correction provides relief. For iron ore from Angola (CN 2601 12 00), indirect emissions were wrongly stated as not applicable. Here, too, the fallback table now applies, and the total value rises slightly from 0.617 to 0.687 tonnes because indirect emissions are now counted. For Tunisia, the tables listed household aluminium articles of heading 7615, which do not fall within the CBAM's scope at all. They are replaced by the correct codes 7616 99 10 and 7616 99 90 with newly assigned values. The regulation also adds country values that were inadvertently omitted in December, including ferro-alloys from Albania, Guatemala, New Caledonia, Zambia and Zimbabwe as well as hydrogen from Gabon and Liberia. Until now, the higher or equal fallback table applied, and for hydrogen from Gabon, for example, the value drops from 17.74 to 10.82 tonnes.

The mark-up columns disappear from the tables

The most visible change is structural. The December version contained three additional value columns per good, showing pre-calculated default values including the mark-up for 2026, 2027 and 2028 onwards. These columns are deleted entirely because the rounding rules applied could lead to inconsistencies. The tables now show only direct, indirect and total emissions. The mark-up logic itself remains unchanged and now sits in the introductory part of the annexes. For cement, iron and steel, aluminium and hydrogen, the mark-up is 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028 onwards, and 1 percent throughout for fertilisers. The final value including the mark-up will be calculated in the CBAM Registry based on the total emissions column. The columns for direct and indirect emissions are provided for information only.

More precision through TARIC codes and production routes

Several changes sharpen the tables. White and grey clinker as well as white and grey hydraulic cement receive separate TARIC codes because different values apply to them. For calcined clay, TARIC code 2507 00 80 80 replaces the previous CN code, since only calcined kaolinic clay falls within the CBAM's scope following the Omnibus amendment. The regulation also adds and corrects the production route indicators that determine which benchmark applies for the free allocation adjustment under Regulation (EU) 2025/2620. Where no route is indicated for a CN code, the benchmark is independent of the production route. Finally, in Annex IV, which applies to precursors of unknown origin, two aluminium values (CN 7616 99 10 and 7616 99 90) are adjusted so that they again correspond to the third country with the highest emission intensity.

What declarants should do now

Anyone who built their 2026 certificate planning on the December tables should reconcile the affected countries and commodity codes against the new annexes. Because of the retroactive effect, the corrected values apply to all imports since 1 January 2026. This does not create acute pressure to act, as the first CBAM declaration for 2026 is not due until 30 September 2027. The new version becomes relevant earlier, though. From 2027, the holding obligation applies, requiring certificates for at least 50 percent of embedded emissions at the end of each quarter, optionally calculated on the basis of default values without the mark-up. And anyone currently weighing whether switching to actual emission values pays off can now compare against corrected figures on a clean basis.

The verification framework is in place, the verifiers are not

Anyone wishing to use actual emission values instead of default values needs an accredited verifier, and that is precisely where things still stall. The legal framework has been complete since December. Implementing Regulation (EU) 2025/2546 governs verification, Delegated Regulation (EU) 2025/2551 accreditation. The national accreditation bodies have opened their procedures, and in Germany, DAkkS has been accepting applications since 23 February 2026. Nevertheless, not a single verifier has been accredited so far. The Commission expects the first accreditations around September 2026, and from 1 September 2026 verifiers can register in the CBAM Registry. In its webinar of 16 July 2026, the Commission accordingly made an active pitch for applicants. For context, it remains important that verification is only required where actual emissions are used. Those using default values do not need a verifier.

In China, data supply is growing faster than verification capacity

For imports from China, the gap is particularly noticeable. China's emissions trading system has covered steel, cement and aluminium since March 2025, and Beijing is pushing data verification in the newly covered sectors to prepare the ground for recognition of carbon prices paid. For now, this is of little use to importers. The individual deduction of a carbon price paid in China under Article 9 requires that emissions are determined on the basis of actual values and verified. As long as no accredited verifiers exist, actual values cannot reliably be obtained. In addition, the site visit is the default under Regulation (EU) 2025/2546, and a waiver is only possible under narrow conditions. Verification capacity on the ground in China therefore still has to be built. For most imports from China, the default value remains the realistic basis in 2026, now in its corrected form.

Outlook

The Commission expects the first verifier accreditations around September 2026 and will publish the list of accredited verifiers on its verification page, while registration in the CBAM Registry opens in parallel on 1 September 2026. The Commission's verification guidance document announced for the summer is also still outstanding. In the coming weeks, declarants should check whether the CBAM Registry correctly reflects the corrected default values including the mark-up.

Support

If you would like to understand how the corrected default values affect your certificate needs for 2026, or whether your supply chain can prepare the switch to actual emission values despite the current lack of accredited verifiers, please get in touch at helge@kolum.earth.