Your EU customer sends an email: “Can you share the embedded emissions data for this product?” If you do not answer, or the data is not reliable, the importer has to calculate with the default values published by the Commission. Those values are set high on purpose, and they get higher every year. So withholding data is not a free option. It becomes a cost on your customer’s invoice, and sooner or later it turns into a price negotiation.
This article compares the two routes, default values and measured actual data. We cover the July 2026 correction, the mark-up schedule and the records you need to move to actual data.
Which regulation, and what changed?
The default values were set by Commission Implementing Regulation (EU) 2025/2621, published on 31 December 2025. There is a separate value for each country and product combination, so a specific figure applies to “this product from Türkiye”.
A correction followed in July 2026. Implementing Regulation (EU) 2026/1740 was published on 31 July 2026 and applies retroactively from 1 January 2026. It fixes technical errors in Annexes I and IV, meaning some table figures and product codes. The Commission’s CBAM page states that its Excel file is for information only and that the regulation itself is binding. If you calculated with an older table, check your numbers again.
The timeline in short:
| Date | What happens |
|---|---|
| 1 January 2026 | Definitive period began; 2026 import emissions are subject to declaration |
| 1 February 2027 | CBAM certificate sales start |
| 30 September 2027 | First declaration and surrender deadline for 2026 imports |
The mark-up: why defaults get more expensive
For most product groups a mark-up applies to default values: 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028. Fertilisers get a lower, 1 percent annual step. Check which group your product falls into, and its own mark-up, in the annexes of the regulation.
The logic is easy to read. The Commission wants to reward producers who supply plant data and discourage those who do not. Because the mark-up grows every year, a default that looks tolerable today can make a real difference by 2028.
Is actual data always lower?
No, and it is worth avoiding big promises here.
- If your plant is more efficient than the sector average, measured values are usually lower than the default. Your customer pays fewer certificates as a result.
- If the plant is old or emission-intensive, actual data can come out higher than the default. Measuring then exposes the number, but at least you know it and can plan improvements.
- Measuring and verifying costs money. For small export volumes the cost can exceed the gain.
So there is no blanket answer. The decision is made product by product, looking at volume and plant efficiency. A simple table helps before deciding: for each product exported to the EU, the default value, an estimated actual value and the annual volume side by side.
What does actual data require?
The method for calculating embedded emissions is in Implementing Regulation (EU) 2025/2547 and in the Commission guidance (Guidance No. 3, August 2026). Verification and accreditation rules are in Regulations (EU) 2025/2551 and 2025/2546. In practice a verifier will ask for records that fall into these groups:
- Installation boundary and process flow. Which line, which product, which intermediate?
- Fuel and electricity consumption. An invoice total is not enough; you need meter data, period and quantity.
- Raw material and precursor records. The embedded emissions of the steel, aluminium, clinker or fertiliser inputs you buy count too.
- Production quantities. Tonnes or units per line, including stock changes.
- Meter and calibration documents. The verifier will ask where the data comes from.
Keeping the calculation method consistent from year to year, and logging every change, matters as well.
Three places where data work usually gets stuck
Scattered spreadsheets. Electricity sits in accounting, output in the MES, raw materials in the ERP, fuel invoices in email attachments. A per-unit emissions figure then takes two weeks, and those two weeks are spent again each time a customer asks.
Period mismatch. The electricity bill follows the calendar month, the production report follows shift periods. The verifier asks for a reconciliation and the gap shows up.
Unknown precursor emissions. If your supplier gives you no emissions data, your own product calculation stays incomplete. That is why supplier data clauses belong in purchase contracts now. Our supplier emissions data article goes into detail.
Where to start: six steps
- Define the scope. Check by customs tariff code whether your EU-bound products fall under CBAM, and confirm the codes against the corrected annex tables.
- Write down the default value. Take each product’s value from the current, corrected table and note the version with the mark-up beside it.
- Estimate the actual value. Make a rough calculation from existing invoices and production records. The goal is direction, not a precise result.
- Rank by volume. Start with products that have high annual exports and a likely lower actual value.
- Build the data flow. Bring meter, ERP and production data into one place. Collecting monthly is far cheaper than collecting at year end.
- Talk to the verifier early. Ask which records they need and in which format. See our earlier verifier article for the verification process.
Where İkiz Eksen fits
Embedded emissions accounting rests on three things: measurement, software and compliance. Without meter and machine data the calculation turns into an estimate. If ERP and production records are not connected, data is gathered by hand every time. If the report format does not meet what the verifier expects, the effort is wasted. We build this chain on a turnkey basis: on-site measurement, a data platform on Microsoft Azure, ERP integration and reporting. With the experience from Qera, 550+ customers and 100+ ERP projects, we work across Türkiye.
Related pages: green transition, digital transition and solutions. If you would like to map your current position together first, get in touch.
Frequently Asked Questions
Is using default values forbidden?
No. An importer can use default values when verified actual data is not available. The problem is that the value, with its mark-up, tends to be high and rises over the years.
Will actual data always lower my certificate cost?
Not necessarily. If your plant emits more than the sector average, actual data can exceed the default. Do a rough calculation first and decide product by product.
Which products get which mark-up?
For most groups it is 10 percent for 2026, 20 percent for 2027 and 30 percent from 2028; fertilisers have a lower 1 percent annual step. Confirm your product’s exact status in the regulation annexes and with your customer.
Does the July 2026 correction affect my calculation?
The correction applies retroactively to 1 January 2026 and covers table figures and product codes. If you used an older table, compare your product’s row with the current text.
Is actual data worth it for a small exporter?
It depends on volume. Measurement and verification carry a fixed cost, so at very small volumes the default can stay cheaper. Run a rough comparison first and confirm the current rules from official sources.
Sources: European Commission CBAM legislation and guidance page; Implementing Regulations (EU) 2025/2621 and (EU) 2026/1740. Dates and rates are stated as of publication; confirm the current position with the official texts and your verifier.