Actual or default CBAM values: decide before the deadline

Decide early whether you will use the Commission's default values or your supplier's own figures, called actual values. Procurement may ask you this, and it can look like a choice for declaration time. For one of the two routes, that is too late.

EU CBAM declarants can report embedded emissionsEmbedded emissionsThe greenhouse-gas emissions released producing a good — direct emissions plus, where applicable, indirect (electricity) emissions — expressed per tonne of good; electricity uses kWh legally and may be converted to MWh operationally. This i with either route, subject to the applicable legal conditions. The choice decides which supplier data you need, how ready you are for verification, how good your calculation is and how much money you risk. The Commission's one-page factsheet makes the choice visible without replacing the detailed rules, and it prompts importers and producers to decide early.

What the two routes mean

The default route uses values that the Commission provides under the applicable framework. It reduces the immediate work of collecting installation-specific emissions data. The trade-off is that defaults may be conservative and may not reflect how a particular installation performs.

The actual-value route uses installation data. The factsheet states that the third-country producer must provide verified data on total embedded emissions when actual values are used, and a supplier declaration does not meet that standard. Monitoring, calculation, records and accredited verification must form a defensible chain.

The two routes work differently

A side-by-side comparison hides the most important difference: one route is a lookup, and the other is a chain.

On the default route, you find which default applies under the current tables. You then record the table version and the legal basis you used.

On the actual-value route, every link must hold at the same time. The producer needs monitoring arrangements and defined system boundariesSystem BoundariesThe incorporated UK document defining which production processes and emissions belong in the UK CBAM calculation boundary.. Production data and precursorPrecursorUpstream CBAM good consumed as input to a complex-good process; listed per route; quantities always monitored per Annex II pt E. information must exist, and an appropriately accredited verifierVerifierAccredited independent third party confirming the SEE is free of material misstatement; any EU or third-country legal person; only values in a verification report count for actuals. Importers receiving "verification reports" from third part must be available in time. If one link is missing, the route is closed to you, however favourable the number looks.

You cannot rebuild that evidence casually at the end of the reporting cycle. The default route is still open on the day you declare. The actual-value route is open only if the work started months earlier.

The factsheet does not say that one route is always better. The right route depends on the legal conditions, the product and precursor calculation and the available data. It also depends on the likely gap between the installation result and the relevant default.

Why the deadline matters

The first declaration and certificate surrender for 2026 imports are due on 30 September 2027.

That date is not when you choose the route, but when the evidence is tested. Importers need enough visibility to know whether the promised actual-value package will arrive in usable form. If you wait until the declaration is due to compare the options, you may lose the practical ability to use actual values at all. Put the decision into supplier engagement and data planning, not only into the final declaration process.

Four questions that settle the route

Start the route assessment with four questions:

1. Which default applies under the current tables?
2. What installation data is available?
3. Can the producer support total embedded emissions with the required records?
4. Is an appropriately accredited verifier available in time?

Run the economic comparison on the live default table and on the installation-specific calculation under the current method. A lower installation value may make actual values attractive, but only if the evidence and verification are adequate. A theoretical saving has no operational value if the declaration cannot rely on the supporting data.

Also identify precursor dependencies and who is responsible for corrections, because the factsheet does not resolve these installation-specific issues.

What it means for importers

The route you can use at declaration time depends on work done long before it. With defaults, the risk is paying on a conservative value. With actual values, the risk is a missing link that closes the route when you need it.

What to do

Turn the choice into a documented workflow for each supplier.

• Segment your suppliers by intended route, and record the missing evidence for each one.
• Where a producer takes the actual-value route, map monitoring, calculation, verification and Registry transfer as one workflow, not four separate tasks.
• Where you use defaults, record the table version and the legal basis, then recheck both when you prepare the declaration.
• Run a documented actual-versus-default comparison for each material supplier route.
• Use the factsheet to explain the decision, and anchor the calculation and the deadline to current legislation and implementing material.

If you prefer the actual-value route, start the producer and verifier work now, because verification is not a final-stage formality.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article explains a Commission factsheet. It is not legal, tax or customs advice.