EU CBAM Actual vs Default Values: A Practical Choice

Someone in procurement asks whether you will use the Commission's default values or the supplier's own figures. It sounds like a decision you can take later, when the declaration is being prepared. For one of the two routes, it is not.

EU CBAM declarants can use Commission default values or actual values when reporting 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, subject to the applicable legal conditions. That reads like a simple choice. In practice it is a decision about supplier data, verification readiness, calculation quality and financial exposure.

The Commission's one-page factsheet is useful because it makes the choice visible without pretending to replace the detailed rules. It also gives importers and producers a prompt to decide early which evidence route they are preparing to support.

What the two routes mean

The default route uses values provided by the Commission under the applicable framework. It can reduce the immediate burden of collecting installation-specific emissions data. The trade-off is that defaults may be conservative, and may not reflect the performance of a particular installation.

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

The two routes are not symmetrical

A side-by-side comparison hides the most important difference between them.

The default route is a lookup. You establish which default applies under the current tables, and you record the table version and the legal basis you used.

The actual-value route is a chain, and every link has to hold at the same time. The producer needs monitoring arrangements. System boundariesSystem BoundariesThe incorporated UK document defining which production processes and emissions belong in the UK CBAM calculation boundary. must be defined. 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. 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 not open to you, however favourable the underlying number looks.

That evidence cannot be reconstructed casually at the end of the reporting cycle. The default route is still available on the day you declare. The actual-value route is available only if the work started months earlier.

The factsheet does not say that one route is universally better. The appropriate route depends on the legal conditions, the product and precursor calculation, the available data, and the potential difference between the installation result and the relevant default.

Why the deadline moves the decision forward

The first declaration and certificate surrender is due on 30 September 2027 for 2026 imports, under the consolidated framework current at the research cutoff. Recheck that date against current consolidated law before operational reliance.

That date is not when the route is chosen. It is when the evidence is tested. Importers need enough visibility to know whether the promised actual-value package is likely to arrive in usable form. Waiting until the declaration is due to compare the options can remove the practical ability to use actual values at all. The decision belongs in supplier engagement and data planning, not only in the final declaration process.

Four questions that settle the route

A useful route assessment starts with four questions:

• Which default applies under the current tables?
• What installation data is available?
• Can the producer support total embedded emissions with the required records?
• 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 reported installation value may make actual values attractive, but only if the evidence and verification are adequate. A theoretical saving is not operationally useful if the declaration cannot rely on the supporting data.

The assessment should also identify precursor dependencies and responsibility for corrections. The factsheet does not resolve those installation-specific issues.

Turn the choice into a documented workflow

Segment your suppliers by intended route, and record for each one the evidence that is still missing. Where a producer is going down the actual-value route, map monitoring, calculation, verification and Registry transfer as a single workflow rather than four separate tasks. Where you are using defaults, record the table version and the legal basis used, 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, but 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. Verification is not a final-stage formality.

Source note: This article is based on the Commission factsheet published in June 2026. The factsheet explains the choice but does not amend the legal method, default tables, verification rules or declaration deadline.