CBAM Benchmarks and Default Values Leaked – How Actual CBAM Data Matters

Alongside the leaked draft implementing regulation on CBAM verification (see our article on CBAM verification), new information vital for the definitive CBAM phase from 2026 has surfaced in recent days. Most notably, details have emerged regarding the calculation of free allocation adjustments that in part determine CBAM certificate purchase requirements, featuring preliminary CBAM benchmarks and a new set of country-specific default values. These default values will be essential for CBAM reporting when importers lack access to verified data from their suppliers.

This article explores the implications of these CBAM updates for importers’ cost exposure. The analysis is based on leaked documentation and should be considered preliminary.

Updates on CBAM Benchmarks

CBAM benchmarks are central to determining the costs associated with importing CBAM goods. They are grounded in benchmarks applied in the European Emission Trading System (EU ETS), reflecting the emission intensity of the most efficient EU facilities. EU ETS benchmarks are designed to ensure that producers covered by the EU ETS do not pay CO₂ costs for emissions up to benchmark levels. For CBAM, establishing a level playing field requires that this exemption be factored into the calculation of the CBAM surcharge applicable to imported goods.

This is managed through the CBAM benchmark deduction: benchmarks are subtracted from embedded emissions to calculate the importer’s CBAM certificate obligations. More on the calculation methodology can be found in our article on Effective CBAM Cost Management. While the European Commission has yet to release the final CBAM benchmarks, the leaked values offer an early insight into what to expect from 2026:

• Applicable CBAM benchmarks will depend on the production processes underlying each CBAM good. When suppliers report emissions, they will assemble a benchmark profile representing the entire process chain. For example, in the iron and steel sector, separate benchmarks exist for steps like melting, continuous casting, and rolling.
• For some goods, CBAM benchmarks will change from 2028 due to adjustments in the methodology of the underlying EU ETS benchmarks.
• Absent actual data, a country-specific ‘default’ benchmark will be applied, reflecting the primary production route in the country of production. For iron and steel, this means differentiated benchmarks for BF-BOF, DRI/EAF, and Scrap/EAF production. Similar distinctions, such as between primary and secondary aluminium, are intended to address issues like the aluminium scrap loophole. However, which production route and benchmark must be used for a specific country has not yet been disclosed.

All leaked CBAM benchmarks remain provisional and will be updated following the revision of the EU ETS benchmarks for 2026–2030. Early analysis suggests a significant decrease in CBAM benchmarks for some production routes compared to initial expectations. We take this expected decrease in EU ETS and consequently CBAM benchmarks into account for the example presented below.

Updates on Default Values

When importers cannot obtain verified (!) CBAM data from suppliers, default values must be used in CBAM declarations. These values are based on the average emission intensity for a product from a particular country and are further increased by a mark-up before use. To date, there is no official confirmation of the precise mark-up, which is expected to be set in a forthcoming regulation in Q4 2025. Based on communications with various sources, carboneer expects an average mark-up of 30 percent. If no country-specific default exists, importers apply the average value among the ten countries with the highest defaults for the product code in question.

In 2023, the JRC published average emission intensities for key trading partners, aiming to cover countries that cumulatively represent over 90% of EU imports per sector. The leak reveals a substantial expansion of country coverage, with values now available for 132 countries. However, not every country, sector, or CN code is included for each country.

 

The new set of country-specific values show that the differences in CBAM cost for products from different countries can be large and the additional mark-up could potentially amplify these differences.

Impact on CBAM Costs: An Example

To illustrate the impact of the updates on CBAM Benchmarks and default values, consider the following scenario:

• A company imports 10,000 tons per year of tubes and pipes from both China and India (CN category 7305) in 2026.
• Lacking actual supplier data, the importer resorts to default values: 1.84 t CO₂/t for China and 4.32 t CO₂/t for India (before any mark-up). Applying a 30% uniform mark-up increases these figures.
• The CBAM benchmark is 1.543 t CO₂/t, assuming the BF-BOF production route and a 6% reduction following the adjustment of EU ETS benchmarks in 2026.
• CBAM certificate prices are forecast between €90 and €110 for 2026.

Model results indicate 2026 imports from China would generate CBAM certificate costs of approximately €800,000 to €975,000 (i.e., €80–97.5 per ton), and from India, €3,700,000 to €4,520,000 (or €370–452 per ton).​

The Value of Actual CBAM Data

With the leaked default values and benchmarks, the value of actual CBAM data from suppliers becomes more apparent. In this calculation, we assume that production processes in both countries correspond to those used to establish the default CBAM benchmark, meaning the same CBAM benchmark applies. If Chinese and Indian suppliers can provide verified emission data matching the country average (i.e., before the mark-up), CBAM costs on Chinese imports in 2026 drop to €300,000–€370,000, and on Indian imports to €2,530,000–€3,100,000.

Figure 2 presents a comparison of CBAM costs for imports in both 2026 and 2034, based on constant import volumes and projected certificate prices between €99 and €224 for 2034. Blue bars represent costs calculated using default values, while green bars illustrate outcomes with actual supplier data. The green scenarios highlight the relative savings achieved by avoiding the 30 percent mark-up.

In absolute terms, switching from default values to actual data yields greater cost reductions for Indian imports. This is primarily because the uniform 30 percent mark-up leads to a higher penalty for countries with greater underlying emission intensities. However, in relative terms, the CBAM benchmark’s non-linear effect is key: actual supplier data reduces CBAM costs by 62% for Chinese imports and 32% for Indian imports. This potentially counter-intuitive result stems from the fact that the verified emission value for Chinese suppliers (1.84 tCO₂/t) is already close to the CBAM benchmark (1.543 tCO₂/t), meaning liabilities nearly disappear. In contrast, for Indian suppliers, the national average (4.32 tCO₂/t) remains well above the benchmark, so savings are significant but less dramatic as a share of total cost.

Summary and Next Steps

The leak of CBAM benchmarks provided some added transparency to the calculation rules for CBAM emissions and costs. While complexities increase, importers, traders and producers are now better positioned to estimate their CBAM exposure and prepare for the definitive phase starting from 2026.

The utilisation of default values might be highly punishing for imports of certain goods from some countries. A structured and clear overview of the cost implications under different scenarios is therefore required for importers to make strategic decisions on purchasing and supplier interaction. Cost-conscious importers should investigate the potential of reducing their CBAM exposure by supporting their suppliers to deliver verified CBAM data.

carboneer offers CBAM cost modelling and management services to help importers and exporters of CBAM goods navigate compliance and maximise cost efficiency. With hands-on experience supporting over 150 producers, carboneer assists companies in sourcing robust CBAM data and developing verification-ready monitoring systems throughout their supply chain. Thanks to this proactive approach, some importing clients now benefit from seamless access to actual emission data across their entire supply chain. For tailored strategies to reduce CBAM exposure and enhance your company’s long-term competitiveness, reach out to discover how carboneer can support your business.