DECISION GUIDE
CBAM Default Values vs Actual Emissions
Using default values is easier; but if your installation’s actual emissions are below the applicable default value, actual data can reduce your estimated CBAM exposure. If actual emissions are higher, the cost can rise too — actual data does not automatically mean a saving. Calculate the difference before deciding.
Last reviewed: 6 September 2026
What is a default value?
Default values are official regulatory values published by the Commission and usable in declarations under the applicable CBAM rules. The applicable value depends on the CN code, the country of origin and — for many goods — the production route; a regulatory mark-up that varies by year may also apply (details below).
EPDlogy provides a free lookup based on the official EU dataset (dataset: IR (EU) 2025/2621 + IR (EU) 2026/1740, updated: 2026-08-10).
Look up your default value →What are actual embedded emissions?
Actual embedded emissions are installation- and product-specific values calculated according to the applicable CBAM methodology: the installation’s direct emission sources, production quantities, the attribution of emissions to processes and products, and — where applicable — precursor data all feed the calculation.
An important caution: a PCF, an EPD GWP result or a corporate carbon footprint is NOT automatically CBAM actual emissions. LCA/EPD/PCF work can contain valuable underlying data, but CBAM has its own methodology, system boundary and data requirements. The box below explains the distinction.
Side-by-side comparison
DEFAULT VALUE
Advantages
- A quicker starting point
- No installation-specific emission calculation needed for the value itself
- Official regulatory dataset
Limitations
- An applicable regulatory mark-up may be added by year
- May be higher or lower than the installation’s real performance
- Less representative of the specific plant
ACTUAL EMISSIONS
Advantages
- Installation/product-specific
- May reflect lower-carbon production
- Can materially change estimated CBAM exposure
Requirements / limitations
- Methodology and data requirements apply
- Documentation is needed
- Verification where applicable
- May result in HIGHER emissions/cost than the default value
Compare: default value × your actual emissions
Enter country, CN code, annual quantity and your own actual emission value to see the two scenarios side by side. The comparison uses the same official data and calculation steps as our CBAM cost calculator; everything runs in your browser.
Your inputs (quantity, actual emissions) stay in your browser; nothing is sent to any server.
Why can the difference be large?
The gap between a default value and an installation-specific result has many drivers: the production route (in steel, scrap-EAF versus blast furnace), the fuel/energy mix where the applicable methodology takes it into account, the embedded emissions of purchased precursors, process efficiency and the country-level default value itself. On the cost side, the regulatory mark-up, the free allocation adjustment (CBAM benchmark) and the certificate price scale the result. Not every factor carries the same weight in every sector.
Default value mark-ups
In the definitive regime, declaring with a default value may require a regulatory mark-up on top, varying by year. The rates in the current dataset (Implementing Regulation (EU) 2025/2621, corrected by (EU) 2026/1740):
For fertiliser goods the mark-up is 1% in all years.
Rates can change by product group and year through legislation; the percentages above are not hard-coded into this page — they are read from the same official dataset the calculator uses.
When may actual data be worth investigating?
Actual-data preparation may be worth investigating if:
- Your installation uses a lower-emission production route (e.g. scrap-EAF, secondary aluminium).
- You suspect the official default value is materially higher than your plant-specific result.
- Your EU sales volume is large — even a small €/t difference compounds annually.
- CBAM €/t exposure is commercially significant for you.
- Your EU customer is asking for installation-specific emissions data.
- Your production/emissions data is already well structured — preparation costs fall.
Actual-data preparation is NOT automatically beneficial. The decision should weigh the potential CBAM difference against the data preparation, monitoring and verification effort. The module above shows the size of the difference; the effort side is specific to your installation.
What is needed to use actual emissions?
The main data and documentation categories under the current CBAM methodology: installation identification, production route, reporting-period production quantities, relevant direct emissions data, precursor information where applicable, the allocation method, monitoring/calculation documentation, supporting evidence and — where applicable — verification requirements. Our steel guide walks through the items one by one.
Is your data ready for verification? Check in 2 minutes →See what the verifier will look at in this data: the CBAM verification process.
Can I use my EPD or LCA result directly in CBAM?
No — not automatically. An EPD or LCA can contain valuable underlying data, but its GWP result cannot be treated as CBAM embedded emissions as-is. Key reasons: different system boundaries, different allocation rules, different product definitions, different reporting methodology, and CBAM-specific precursor and installation requirements.
That does not make your EPD data useless: a well-built common factory data foundation, mapped correctly, can support several frameworks — EPD, PCF and CBAM — together.
A numerical example: Türkiye, CN 7208, 1,000 tonnes, 2026
The example below is generated at build time from the same official datasets the calculator uses. The 1.8 tCO₂e/t in the actual column is an illustrative user-entered value — not a real company value.
| Scenario | €/t | Annual (€) |
|---|---|---|
| A) Official default value scenario (2.428 + 10% mark-up) | 100.50 | 100,503 |
| B) Illustrative actual emissions scenario (1.8 tCO₂e/t — illustrative user-entered value) | 34.95 | 34,949 |
| Difference — 65.2% lower | -65.55 | -65,554 |
Illustrative estimate, not an official CBAM declaration. The same free allocation adjustment is deducted in both scenarios; certificate price: Q2 2026: €75.28/tCO₂e.
Try your own value →For an explanation of every step in the calculation: the step-by-step guide.
Frequently asked
What is a CBAM default value?
Official values published by the Commission, usable in declarations under the applicable CBAM rules. The applicable value depends on the CN code, the country of origin and, for many goods, the production route; a regulatory mark-up may be added by year. Source: Implementing Regulation (EU) 2025/2621 (corrected by (EU) 2026/1740).
Is using actual emissions mandatory?
No — declaring with default values is possible under the applicable rules. Actual emissions are an option for installations that meet the conditions; which path makes sense depends on the size of the difference and the effort of preparing the data.
Do actual emissions always mean lower cost?
No. Actual emissions may be lower or higher than the applicable default value. If lower, the cost falls; if higher, it rises. That is why the two scenarios should be compared before deciding — the module on this page does exactly that.
Why can the default value be higher than my actual emissions?
Default values are set at country and product-group level, and a regulatory mark-up may be added by year. If your installation produces on a lower-emission route (e.g. scrap-EAF), the country-level value can sit above your plant’s real performance.
Can I use the GWP value from my EPD in CBAM?
Not directly: an EPD/LCA has a different system boundary, allocation rules and product definition than the CBAM methodology. The underlying installation data behind your EPD, however, can be a valuable foundation for the CBAM calculation — with correct mapping.
Do actual emission values need to be verified?
Where actual emissions are used in the definitive regime, the verification requirements of the applicable CBAM rules must be satisfied. See the Commission’s verification guidance for the official requirements; you can gauge your readiness with our free check.
Is actual data worth it?
It depends on the installation. First calculate the potential CBAM difference (the module on this page), then weigh it against the data preparation, monitoring and verification effort. A large difference with well-structured data is worth investigating; a limited difference can make default values the reasonable choice.
Free CBAM tools
The natural sequence: look up your value → compare here → refine in the full calculator → test your verification readiness.
Default Value Lookup →
The current official value for country + CN code
CBAM Cost Calculator →
Multi-product calculation, projections, PDF report
CBAM Scope Checker →
Is your CN code covered?
Verification Readiness Check →
Your data readiness in 10 questions
Related pages: CBAM iron & steel guide · Current CBAM certificate price
Need support preparing your actual emissions data according to the CBAM methodology?
Contact EPDlogy →Sources
This page is informational and not an official EU source; work from the current official texts when preparing declarations.
- Regulation (EU) 2023/956 — the CBAM Regulation (provisions on the calculation and verification of embedded emissions, Annex IV)
- Implementing Regulation (EU) 2025/2621 + correction (EU) 2026/1740 — default values and mark-ups
- Implementing Regulation (EU) 2025/2620 — the free allocation adjustment (Annex, Equation 6)
- Commission Guidance No. 3 — CBAM methods for the calculation of emissions embedded in goods (14 Aug 2026)
- Commission Guidance No. 4 — calculation of the free allocation adjustment (14 Aug 2026)
- Commission Guidance No. 5d — sector-specific guidance: iron and steel (for the steel example) (14 Aug 2026)
Certificate price: the Commission’s official quarterly price (Q2 2026: €75.28/tCO₂e).
Last reviewed: 6 September 2026