Default values or actual emissions: which costs your buyer less
How the EU default with its mark-up compares with your own verified figure, with a worked example, and when verifying is worth the cost.
Checked against the EU rules on 6 October 2026.
Your EU buyer can calculate the CBAM cost of your goods in one of two ways: with the EU default value for your product and country, or with your actual emissions checked by an accredited verifier. The choice is the single biggest lever you have on the price your buyer is willing to pay.
The default route
The Commission publishes a default value for every CBAM product code and country, in tonnes of CO2e per tonne of product. They are based on the more carbon-intensive producers, and a mark-up is added: 10% in 2026, 20% in 2027 and 30% from 2028. The importer then deducts a share of the EU benchmark, reflecting the free allowances EU producers still receive. That share falls from 97.5% in 2026 to zero in 2034.
The actual route
With actual emissions the importer uses your plant's own figure: direct emissions from fuels and processes plus the embedded emissions of the precursors you buy, per tonne of product. No mark-up applies. The figure must follow the EU monitoring rules and be confirmed by a verifier accredited in the EU.
A worked example
Take 100 t a year of Indian wire rod at €75 per tonne of CO2. Suppose the mill's verified figure is 2 t CO2e a tonne.
| Import year | With the default | With 2 verified | Saving |
|---|---|---|---|
| 2026 | €25,253 | €5,026 | €20,228 |
| 2028 | €32,426 | €5,793 | €26,633 |
Try your own figure: the cost calculator has an optional box for verified emissions and shows the saving year by year. The calculator's actual figure is an approximation, because the exact free allocation deduction depends on your process and precursors.
When verifying pays off
- Your figure is clearly below the default, as is common for processors using scrap or cleaner precursors.
- Your EU volumes are large enough that the saving outweighs the verifier's fee.
- You can get verified figures from your precursor suppliers, or their precursors are a small part of the total.
It may not pay off if your plant runs close to or above the default, for example a coal-fired furnace with high fuel use. Then the default can be the cheaper route for your buyer, and the calculator will tell you so.
Read next: how the cost changes year by year to 2034.
General information for planning, not legal, tax or customs advice. See the disclaimer.