CBAM Default Values 2026: How They Work, the Built-In Mark-Up, and What Changed on 31 July

Quick answer: CBAM default values are the emission intensities the EU assigns to your imports when you cannot provide verified actual data from the producing installation. They are set per product and per country in Implementing Regulation (EU) 2025/2621, they carry a deliberate mark-up of 10% in 2026 rising to 30% by 2028, and the Commission already replaced the annexes once, on 31 July 2026, with retroactive effect from 1 January. If your cost model still runs on the December figures, it is wrong.

What default values are, legally

The Carbon Border Adjustment Mechanism prices the greenhouse gases embedded in imports of iron and steel, cement, aluminium, fertilisers, hydrogen and electricity. The bill depends on one number above all: the emission intensity attached to each tonne you import. When the importer can produce installation-level data verified by an accredited verifier, that actual figure applies. When it cannot, the fallback defined under Article 7 of Regulation (EU) 2023/956 kicks in: the default value.

The definitive figures arrived late. Implementing Regulation (EU) 2025/2621 was published on 31 December 2025, one day before the definitive regime started, in annexes running to well over a thousand pages. A spreadsheet version followed in February. Compliance teams spent January reading law that was already in force.

When defaults apply

Two situations, in practice. First, the supplier provides no usable data at all. Second, the supplier provides data that has not been verified: since 1 January 2026, actual emissions may only be used in a CBAM declaration if an accredited third-party verifier has signed off on them. Unverified spreadsheets from a plant, however honest, count for nothing. No verification means default, and default means the country-level average plus the mark-up.

The built-in mark-up

Defaults are not neutral estimates. The regulation adds a deliberate surcharge on top of the country average, designed to make measurement and verification the cheaper path:

Fertilisers get a reduced mark-up of 1%, a concession to how hard actual data is to obtain across chemical supply chains. For everyone else, the message is explicit: staying on defaults gets more expensive every year, on top of the EU ETS price trajectory and the gradual phase-out of free allocation through 2034.

How a country gets its number, and why some countries get none

Country-specific values are built from the best data available to the Commission, drawing on Joint Research Centre estimates and on the millions of data points collected during the 2023 to 2025 transitional reporting phase. Where neither source is considered reliable enough, the regulation prescribes a punitive substitute: the average of the ten exporting countries with the highest emission intensities for which reliable data exists.

Some origins received no national value at all and fall into an "other countries and territories" bucket. The most consequential example is cement from Turkey, the EU's largest cement and clinker supplier at 4.8 million tonnes in 2025. With no Turkish national value, unverified Turkish Portland cement carries the other-countries default of 1.584 tCO2 per tonne for 2026, which Argus priced at almost 83 euros per tonne at February ETS levels. Origins that did receive national values sit lower: Ukraine at 1.518, Algeria at 1.430, Egypt at 1.419. Turkish industry data puts actual kiln performance around 0.88 tCO2 per tonne, roughly half the default it is charged at. That gap is not an accident of rounding. It is the cost of not verifying.

The 31 July 2026 correction, and why it matters to you

On 31 July 2026 the Commission published Implementing Regulation (EU) 2026/1740, correcting IR 2025/2621 by replacing Annex I and Annex IV in full. The corrected values apply retroactively from 1 January 2026. They were released as a large PDF rather than a structured dataset, with no tracked-changes version, which leaves every CBAM team to diff a thousand pages by hand.

Three practical consequences. Any cost model, ERP table or contract clause built on the December figures needs re-checking line by line. Provisions booked for 2026 imports may be over- or under-stated. And the episode sets a precedent: these numbers can move again, mid-year, with retroactive effect.

What this means for cost planning

Treat the default value as the price of doing nothing. It is the ceiling you accept for every product-country pair where no verified actual exists, and the mark-up schedule guarantees that ceiling rises through 2028. The real planning question is the spread between your default and your supplier's actual intensity, per product, per origin. That spread, multiplied by your tonnage and the certificate price, is the money on the table. We break the calculation down, with cement and steel worked cases, in the companion article on the default versus actual cost gap.

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