In the absence of actual data, default values play a key role in determining embedded emissions of CBAM goods and costs for importers. The EU Commission has defined country-specific default values for commodity codes subject to CBAM. Overall, there are 3 sets of default values.
(Last update on 03/03/2026)
Emissions as key element in CBAM
They have been long awaited for: the default values for emissions under the EU Carbon Border Adjustment Mechanism (CBAM). The EU published these in Implementing (IR) Regulation EU 2025/2621 on December 31, 2025 –one day before the start of the definitive period. An XLS-version was made available in February.
CBAM requires importers as CBAM declarants to purchase CBAM certificates based on the embedded emissions in CBAM goods: aluminum, cement, fertilizer, iron & steel, hydrogen, and electricity. Large cost differences are possible depending on the emissions value and also carbon prices for CBAM certificates.
CBAM emissions are based on the concept of specific embedded emissions (SEE), which are measured in tons of CO2 equivalent per unit of the CBAM goods. CBAM differentiates between:
- Direct emissions released during the production of goods – relevant for all CBAM goods
- Indirect emissions from the production of electricity that is consumed during the production process of these goods – relevant for fertilizer and cement.
In their annual CBAM declarations (for the first time due in September 2027 for the import year 2026), importers need to indicate embedded emissions of imported goods. These emissions are to be calculated in accordance with the methods laid out in IR 2025/2547 either using actual values or default values.
Default values are set by the EU Commission. A first set of values was published for the transitional period at the end of 2023. Legally binding default values for the definitive period are now set in IR 2025/2621. They are to be revised periodically through the implementing acts – at the latest by December 2027.
3 sets of default values
In the CBAM there are 3 sets of default values: (i) for direct emissions of non-electricity goods, (ii) for indirect emissions of non-electricity goods, and (iii) for imported electricity.
Direct emissions of non-electricity goods
Standard approach: Embedded direct emissions are to be determined based on actual data from the installations where these goods have been manufactured. These actual emissions need to be monitored, reported and verified according to the CBAM methods.
Alternatives: When no actual emissions value according to these CBAM requirements is available, specific embedded emissions are to be determined based on default values. Contrary to the transitional period, there are no limits for the use of default values.
Default data: Country-specific default values for specific embedded emissions of non-electricity CBAM goods are set in Annex I of EU IR 2025/2621. They represent the average emission intensity of each exporting country and for each CBAM good based on the most up-to-date and reliable information.
In the event that neither data obtained by the Joint Research Centre nor data collected during the transitional period is considered sufficiently reliable, the default values should be based on the average of the ten exporting countries with the highest emission intensities for which reliable data can be applied.
Application: To incentivize the use of actual data, default values are to be applied with a mark-up. It varies by sector: For aluminum, cement, and iron & steel the mark-up increases from 10% in 2026 to 30% in 2028. Due to the difficulty of obtaining actual data across complex chemical supply chains, it is set at only 1% for fertilizer.
Indirect emissions of non-electricity goods
Standard approach: Embedded indirect emissions are to be determined based on default values for the emission factor of electricity consumed in the production process of CBAM goods (tCO2e / MWh).
Default data: Country-specific default values for these emissions factors are defined in Annex II of EU IR 2025/2621. They are calculated based on the average of the emission factor of the country-of-origin electricity grid – for the most recent 5-year period for which reliable data is available. Values are based on data from the IEA.
Alternatives: Actual emission factors for electricity may be used if there is a direct technical link between the electricity-generating source and the installation producing the CBAM good or in case of a power purchase agreement through which electricity is provided to the installation.
Application: To calculate embedded emissions, this emissions factor is to be multiplied with the electricity consumed during the production of the imported goods. These consumption levels are to be determined based on actual data.
At the moment, indirect emissions are only required for CBAM goods in the cement and fertilizer sector.
Emissions of imported electricity
Standard approach: Embedded emissions of imported electricity are to be determined based on default values of the CO2 emission factor (tCO2e / MWh).
Default data: Country-specific default values for these emissions factors are defined in Annex III of EU IR 2025/2621. They are calculated on the basis of the average of the yearly CO2 emission factors for the most recent five-years period for which reliable data is available. These values are based on data sourced from the IEA.
Alternatives: Actual emission factors can be used if the imported electricity meets cumulative criteria such as: (i) being covered by a qualifying power purchase agreement, (ii) originating from an installation with a physical or congestion‑free connection to the EU grid, (iii) produced below fossil CO2 intensity threshold, etc.
Application: This value is to be multiplied by the amount of electricity imported into the EU to calculate the embedded emissions for which CBAM certificates are to be purchased.
The role of default values
The application of CBAM default values can result in higher emissions and hence costs – especially when the production of CBAM goods or electricity already benefits from greener production processes and technology. Nevertheless, CBAM default values play a crucial role in ensuring the working of CBAM.
In reality, many non-EU producers will face challenges in providing CBAM‑compliant emissions data. Establishing monitoring systems and data collection across complex international supply chains takes time. Accredited verifiers may not always be available. In these situations, default values offer a technical interim solution.
Moreover, not for all production processes and precursors the effort related to emissions monitoring, reporting and verification is cost-efficient. Especially, for production steps that make a smaller share of emissions, these costs may be disproportionately high. In these contexts, default values offer a cost-saving option.
Finally, default values create a reference point for cost calculations. In the absence of verified emissions data, importers face high uncertainty regarding embedded emissions. Default values enable the calculation of CBAM certificate needs and costs. They offer an upper cost boundary.
The use of default values for countries with high values comes with practical challenges for purchasing, sales and finance departments. Nevertheless, they are still a key step in CBAM calculations and financial planning.
Sources and further information:
- EU: Regulation Establishing CBAM (2023/956)
- EU: Implementing Regulation for Methods for Embedded Emissions (EU 2025/2547)
- EU: Implementing Regulation for Default Values (EU 2025/2621)
- European Commission: CBAM Emissions
