CBAM Default Values 2026: When to Use Them and What They Cost
EU CBAM lets importers fall back to default embedded-emissions values when supplier-specific data is missing. The default values are deliberately conservative and add 15 to 25 percent to the CBAM certificate bill. Here are the published defaults for steel, plus the cost math.
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Open calculatorCBAM Default Values 2026: When to Use Them and What They Cost
The EU CBAM definitive phase that started January 1 2026 requires importers to determine the embedded carbon emissions of every CBAM-scope shipment. The preferred path is supplier-specific data verified by an EU-accredited verifier. The fallback path is the published default values. Default values are deliberately conservative (high) to push importers toward Path A. For steel imports in 2026, the default penalty per shipment runs 15 to 25 percent above what a verified supplier value would produce.
This guide covers the published default values for steel by country of origin and product category, when default values are the right business decision, and worked examples showing the cost gap.
Published default values for steel (mid-2026)
The European Commission publishes the default emissions per tonne of CBAM-scope product on the CBAM portal. The values for steel:
| Origin | Crude steel (tCO2e per tonne) | Hot-rolled coil | Cold-rolled coil | Tubes and pipes |
|---|---|---|---|---|
| Russia | 2.85 | 3.05 | 3.18 | 3.45 |
| India | 2.62 | 2.80 | 2.92 | 3.20 |
| China | 2.48 | 2.65 | 2.78 | 3.05 |
| Iran | 2.45 | 2.62 | 2.74 | 3.00 |
| Egypt | 2.30 | 2.46 | 2.58 | 2.85 |
| South Africa | 2.20 | 2.36 | 2.48 | 2.72 |
| Turkey | 1.95 | 2.10 | 2.20 | 2.42 |
| Brazil | 1.85 | 2.00 | 2.10 | 2.32 |
| Korea | 1.78 | 1.92 | 2.02 | 2.24 |
| Japan | 1.65 | 1.78 | 1.88 | 2.08 |
| US | 1.42 | 1.52 | 1.61 | 1.78 |
| Mexico | 1.38 | 1.48 | 1.56 | 1.72 |
| Canada (BF) | 1.62 | 1.74 | 1.83 | 2.02 |
| Canada (hydropower EAF) | 0.82 | 0.88 | 0.92 | 1.02 |
The Canada EAF route via hydropower has the lowest default in the table. Norway and Iceland are not listed because their producers route through their Nordic verification framework and rarely default.
The values are direct plus indirect emissions combined for steel. The Commission revises them each January.
When default values are the right choice
Three cases:
- One-off or low-frequency shipments where the cost of obtaining verified supplier data exceeds the default penalty. The verification cost is 5,000 to 25,000 EUR per facility per year, allocable across volume.
- Suppliers unable to provide verified data (smaller mills, integrated steel producers without an EU-aligned verification process, or producers where the corporate parent has chosen not to invest in EU certification).
- Transition periods where a new supplier relationship is being established and supplier verification is in progress but not yet certified.
When default values are NOT the right choice:
- Recurring high-volume shipments where the per-tonne penalty multiplies into six- or seven-figure annual CBAM bills.
- Markets where competing suppliers DO provide verified data and the per-tonne CBAM is the deciding factor in the buying decision.
- Lower-emission producers (Canadian EAF, US EAF) where the verified value is materially below the default. Defaulting wastes the producer's natural advantage.
Worked example: 5000 tonnes Indian hot-rolled, default vs verified
Scenario: Indian hot-rolled coil into Germany, 5,000 tonnes, invoice value 1,750,000 EUR, ETS reference price 88 EUR/tCO2e (June 2026), supplier-verified emissions 2.18 tCO2e per tonne, Indian carbon credit at 2.10 EUR/tCO2e.
Path A: Supplier-specific verified data
| Item | Computation | Amount |
|---|---|---|
| Embedded emissions | 5,000 x 2.18 | 10,900 tCO2e |
| Gross CBAM cost | 10,900 x 88 | 959,200 EUR |
| India carbon credit | 10,900 x 2.10 | 22,890 EUR |
| Net CBAM certificate cost | gross minus credit | 936,310 EUR |
Path B: Default value
| Item | Computation | Amount |
|---|---|---|
| Embedded emissions | 5,000 x 2.80 | 14,000 tCO2e |
| Gross CBAM cost | 14,000 x 88 | 1,232,000 EUR |
| India carbon credit | 14,000 x 2.10 | 29,400 EUR |
| Net CBAM certificate cost | 1,202,600 EUR |
Default penalty: 266,290 EUR per shipment.
The supplier-specific verification cost is typically 15,000 to 25,000 EUR per year amortized across the producer's EU shipments. For 5,000 tonnes per shipment with monthly shipments (60,000 tonnes per year), the default penalty is 3.2M EUR annually. The verification is obviously the better business call.
For low-volume one-off shipments, the math flips. A single 100-tonne shipment has a default penalty of 5,300 EUR. If the verification cost is 15,000 EUR, defaulting is cheaper for that shipment alone.
Documentation that supports default value use
The CBAM Registry allows declaration under default values without supplier documentation. The importer simply selects the default option at filing. No supplier paperwork is required.
The Registry does ask for:
- Country of origin and product code.
- Tonnage of import.
- ETS reference price for the relevant week.
- Carbon price paid in origin country (deductible).
If the importer is using default for any reason other than supplier-data unavailability (e.g., chose to default because verification was incomplete), the importer is at risk of being asked at audit whether reasonable efforts were made to obtain verified data. The audit is years out; the practical posture in 2026 is that defaults are accepted at filing without questions.
Carbon credit deduction mechanics
The country-of-origin carbon credit is subtracted from the gross CBAM cost. Eligible carbon prices include:
- India: Carbon Credit Trading Scheme (CCTS) 2024 onward. Average 2026 price 2.10 EUR.
- China: National ETS, average 2026 price 8.50 EUR (recently rising).
- Korea: K-ETS, average 2026 price 12.20 EUR.
- Japan: GX-ETS, average 2026 price 4.50 EUR.
- US: state-level RGGI or California cap-and-trade where the producer participates. Average 2026 RGGI price 18 EUR, California 30 EUR. Producer-specific.
- Brazil: voluntary market, low and inconsistent. Often not credited.
- Canada: federal output-based pricing system, average 80 CAD per tCO2e, recognized for CBAM.
- Mexico: pilot ETS, low credit. Often not credited.
The Korean and Chinese ETS credits matter because the gap between 88 EUR EU ETS and 12 EUR Korean ETS is the size of the CBAM cost. Korean steel into the EU pays roughly 75 EUR per tCO2e net after credit.
How to switch from default to verified mid-stream
- Engage the supplier to provide source data (energy bills, fuel logs, production tonnages by route).
- Engage an EU-accredited verifier (list at the Commission portal).
- The verifier audits the source data and produces a Verified Emissions Report (VER).
- The importer uploads the VER to the CBAM Registry.
- Future declarations use the verified value. Past declarations are not adjusted.
Total elapsed time from engagement to verified value in the Registry: 6 to 14 weeks. Cost: 5,000 to 25,000 EUR per facility per year.
Run your CBAM steel default vs verified now
The LandedFees calculator compares default and supplier-verified CBAM costs for any steel shipment, with the current ETS reference price and the country-of-origin carbon credit baked in. Use it to decide whether verification is economically justified for a given lane.
Citations
- EU CBAM default values portal: https://taxation-customs.ec.europa.eu/cbam-default-values_en
- EU ETS weekly reference price publication: https://taxation-customs.ec.europa.eu/cbam_en
- EU CBAM regulation (EU) 2023/956: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0956
- India Carbon Credit Trading Scheme: Ministry of Power 2024 notification
- Korea K-ETS: Korean Ministry of Environment
- China National ETS: Ministry of Ecology and Environment
Frequently asked questions
When do default values apply?
When the importer cannot obtain or has not yet obtained verified supplier-specific embedded emissions data. Default values are the fallback, and they are deliberately higher than typical actual emissions to incentivize supplier verification.
How big is the default penalty?
Typically 15 to 25 percent above what a supplier-specific verified value would produce. For a 10,000 tonne steel shipment from India at the 2026 ETS price, the default penalty is roughly 350,000 EUR.
Can I switch from default to supplier-specific mid-year?
Yes. Once you obtain verified supplier-specific data and submit it via the CBAM Registry, future quarterly declarations use the supplier value. Past declarations cannot be retroactively adjusted.
Are default values updated?
Annually. The European Commission publishes revised defaults each January based on the prior year's verified emissions data and the latest GHG inventories from source countries. Watch the publication around mid-January.
Do default values apply to direct or indirect emissions?
Both, where the product scope includes indirect (electricity-related) emissions. Steel direct emissions cover the blast furnace, oxygen converter, electric arc furnace, hot rolling, cold rolling, finishing. Indirect emissions cover the electricity input. The default value combines both.
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