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.

Figure 1: Countries highlighted in green have available leaked default values for at least one CBAM sector. Source: JRC Report.

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.

Figure 2: Estimated CBAM certificate costs for imports of tubes and pipes (CN Code 7305) from China and India using default values (blue) and actual values at the country-specific emission intensity (green). Source: carboneer CBAMCC Model.

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.

Since 20 October 2025, the new EU regulation (2025/2083) on the simplification of the CBAM system has been in force. In this article, we explain the most important changes for importers and producers of CBAM goods.

Key Amendments at a Glance

• De Minimis Exemption: Companies importing less than 50 tonnes of CBAM goods annually into the EU during 2026 are fully exempt from CBAM reporting obligations. This exemption does not apply to imports of hydrogen and electricity. In 2025, the de minimis rule of 150 euros per delivery continues to apply.
• Mandatory Authorization from 2026: Starting in 2026, companies intending to import more than 50 tonnes of CBAM goods annually into the EU must obtain the status of “Authorized CBAM Declarant.” Applications must be submitted no later than 31 March 2026 to avoid penalties and import restrictions.
• Commencement of Certificate Trading: Trading of CBAM certificates via the Common Central Platform (CCP) will begin on 1 February 2027. However, certificates must already be acquired for imports made in 2026 and submitted in 2027.

New Threshold: Single-Mass-Based Threshold

To determine CBAM obligations, the newly introduced Single Mass-Based Threshold (MBS) now applies. Companies whose annual CBAM goods imports fall below this threshold are fully exempt from CBAM requirements. The MBS is calibrated to capture at least 99% of imported grey emissions in CBAM goods (based on standard values). The European Commission will review and, if necessary, adjust the threshold annually. Any changes apply from the following year, provided the adjustment amounts to at least 15 tonnes. For 2026, the MBS is set at 50 tonnes of CBAM goods. If the threshold is exceeded during a calendar year, CBAM obligations apply retroactively to all imports of that year, including those below the threshold. In 2025, the de minimis rule of 150 euros per delivery continues to apply. We recommend that EU importers contact the national authorities in their respective countries to obtain detailed information on the reporting requirements for the remaining time of the transitional period.

Application Process: Authorized CBAM Declarant

Importers may import CBAM goods in 2026 without having obtained Authorized CBAM Declarant status, provided the application is duly submitted by 31 March 2026. If the application is rejected and CBAM goods exceeding the MBS were imported, penalties will apply to all imports made in 2026 (see section on Sanctions).

Updates to Certificate Management

CBAM certificates may only be acquired from 1 February 2027 via the Common Central Platform (CCP). No acquisition will be possible prior to this date. Nonetheless, certificates must be obtained for 2026 imports and submitted in 2027. Thus, procurement of certificates for 2026 imports will occur retroactively in 2027. Certificate prices for 2026 imports will be based on the average quarterly prices in the EU Emissions Trading System 1 (EU ETS 1) during that year. From 2027 onward, importers must demonstrate, on a quarterly basis, a security reserve of CBAM certificates equivalent to 50% of the grey emissions imported during the current calendar year.

Revised Deadlines

The regulation introduces the following changes to deadlines:

• Submission of CBAM Declarations and Certificates: No later than 30 September of the following year.
• Buyback Requests for CBAM Certificates: Must be submitted by 31 October, provided any certificates were submitted during the current year. A maximum of certificates equivalent to the 50% security reserve may be returned. If the MBS was not exceeded, full return is permitted.
• Certificate Expiry: Certificates from the penultimate calendar year will expire on 1 November, thereby significantly extending their validity period.

Emissions Calculation and Paid CO₂ Prices

Beginning in 2026, importers will have the flexibility to either report actual and verified CBAM data from their supply chains or rely on default values. Unverified actual data is must not be used in CBAM declarations. The European Commission is expected to publish the applicable default values for the definitive period, covering multiple countries. These values will include a penalizing mark-up designed to incentivize the use of verified actual data. In cases where no default value is available for a specific CN code and country, importers must apply the average default value of the ten worst-performing exporting countries.

Precursors originating from the EU are considered emission-free and are no longer included in CBAM emissions calculations. Effectively paid CO₂ prices along the supply chain (less any refunds or discounts) may still be credited. The EU will introduce country-specific standard values for effectively paid CO₂ prices, which may be used in the absence of verifiable actual data.

Sanctions

Sanctions continue to be aligned with the EU ETS 1 regulations (currently approx. €135 per tonne of CO₂ not reported or incorrectly reported). National authorities may reduce penalties if the error is demonstrably attributable to external auditors or foreign authorities. Payment of a penalty does not exempt the importer from submitting the required CBAM certificates.

Companies importing CBAM goods without Authorized CBAM Declarant status face significantly higher penalties: three to five times the standard rate. In such cases, the obligation to submit CBAM certificates retroactively is waived. A reduction in penalties is possible if the MBS was exceeded by less than 10%.