CBAM Default Values
Why CBAM default values are not a single number per CN code, and how country, route, year and emission dimension matter.
Next step
See methodology sourcesDirect answer
CBAM default values are official fallback factors. They cannot safely be published as one emissions number per CN code.
Official defaults vary by dimensions such as year, country or region, CN/goods class, production route, and direct versus indirect emission type.
Who is affected
Exporters and operators estimating emissions before full monitoring evidence exists, importers modelling financial exposure, and consultants who must avoid inventing SEO-friendly single-factor tables.
Regulatory rule
Default values are permitted only under the conditions set by the applicable CBAM implementing rules. Using a default does not remove the need to document the pathway choice and evidence limitations.
Dimensional dependence means two goods with the same CN digit string can still require different default lookups when route, country, or emission type differs.
2026 definitive-period impact
In the definitive period, default-value misuse becomes a declaration-quality risk, not only a transitional learning issue. Wrong dimensional selection flows into the annual package due by 30 September 2027 for 2026 imports.
Required data before using a default
At minimum, lock:
- Goods CN classification and reporting period
- Installation country and production route
- Whether the claim is direct, electricity-related indirect, or both
- The official default dataset version used by the ruleset
- Why actual values were not available or not used
Decision tree
- 1. Prefer actual values when installation evidence can support verification.
- 2. If using defaults, identify every regulatory dimension required by the published table — do not collapse to CN-only.
- 3. Record the ruleset/default dataset version in the methodology decision log.
- 4. Flag mark-ups or conservative adjustments when the rules require them.
- 5. Do not publish or seal a single invented factor as if it were official.
Practical example
A fertiliser exporter lacks complete laboratory evidence for one intermediate. The team selects the official default path for that goods class, country group, route and emission type under the pinned ruleset — and records why actual values were incomplete — instead of pasting a blog “average tCO2e/t” into the dossier.
Common errors and risks
- Publishing one default per CN on a marketing page
- Ignoring country/route/year dimensions
- Treating defaults as verified actual emissions
- Mixing transitional guidance with definitive-period default tables
Official EU sources
Use the versioned official default-value sources referenced by CBAMValid rulesets and EUR-Lex implementing acts — not secondary calculators that flatten dimensions.
How CBAMValid handles it
CBAMValid binds calculations to versioned rulesets and records method decisions. It refuses to invent a single SEO factor per CN and keeps actual/default pathway explicit in the sealed package.
Product boundary
CBAMValid does not publish unofficial default tables as regulatory truth and does not guarantee that a default pathway will be accepted without independent verification where required.
Regulatory basis / last review
For 2026 imports, the first CBAM declaration and corresponding certificate surrender deadline is 30 September 2027.
CBAMValid prepares operator evidence packages for independent accredited verification. It does not issue an accredited verification opinion, EU approval, customs approval, or registry acceptance.
- REG_2023_956: Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism
- IMPL_2025_2547: Commission Implementing Regulation (EU) 2025/2547 of 10 December 2025 laying down rules for the application of Regulation (EU) 2023/956 as regards the methods for the calculation of emissions embedded in goods
Last content review: 2026-07-26