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Default values vs verified values: Understanding emissions data under CBAM

Under both EU and UK Carbon Border Adjustment Mechanism (CBAM) regimes, the way emissions are calculated has a direct and material impact on cost and compliance. One of the most important distinctions for affected businesses is the difference between default emissions values and verified emissions values. In this article we explain how these values work, when they apply and the risks associated with relying on defaults.

What are default emissions values?

Default values are standardised emissions figures set by regulators and applied where verified data is not available or cannot be substantiated. They are intended as a fallback rather than a preferred option.

In most cases, default values are deliberately high. They are designed to reflect higher‑end emissions assumptions to discourage businesses from relying on them instead of providing accurate data. An example is that commodity code 73182900 from China has a current default value of 3.012 tCO₂/t meaning that an importer of this product would be paying €142.37 of CBAM costs per tonne on Default values.

What are verified emissions values?

Verified values are calculated using actual production data from the manufacturing installation where the goods are produced. This data must be calculated in line with CBAM methodology and supported by documentation that demonstrates how the emissions figure was derived.

In many cases, verified values may also need to be confirmed by an independent verifier, particularly as CBAM regimes move into their definitive phases. This set of data is not currently available to EU or UK importers, but it is expected to made available in Q3 of 2026. Therefore businesses are forecasting based on default as a worst case scenario.

Why does the difference matter?

The choice between default and verified values can have a significant cost impact. Default values are often higher than real‑world emissions, which means they can result in a higher CBAM charge or tax liability.

Beyond cost, reliance on default values can also create commercial risk. EU and UK customers may prefer suppliers who can demonstrate verified, lower‑carbon production, particularly where CBAM costs are passed through supply chains.

What are the challenges when using verified data?

Gathering verified emissions data is not always straightforward. Challenges can include limited data availability from overseas suppliers, differences in measurement standards, or a lack of familiarity with CBAM calculation methodologies.

Where supply chains are complex or involve multiple processing stages, understanding which emissions are in scope - and how they should be allocated - can require careful analysis.

Default values: a last resort, not a strategy

While default values may be used where verified data genuinely cannot be obtained, they should not be seen as a long‑term solution. Over‑reliance on defaults can lead to higher costs, reduced competitiveness and increased scrutiny from customers or authorities.

As CBAM regimes mature, regulators are expected to apply greater scrutiny to emissions data quality, making early investment in verified data processes increasingly important.

Looking ahead, what does it mean for me?

The direction of travel is clear: verified emissions data will become the norm rather than the exception. Businesses that take early steps to understand their emissions profile and build reliable data flows will be better positioned to manage CBAM obligations and wider carbon‑related trade measures.

What should I do now?

Identify where default emissions values are currently being used within your EU or UK CBAM reporting, either directly or through your suppliers.

Engage with suppliers early to understand what emissions data is available and whether it can be aligned with CBAM calculation requirements.

Assess the potential cost difference between default and verified values to understand where investment in better data could deliver meaningful savings.

Given the technical nature of emissions calculation and verification, many businesses choose to work with certified CBAM training or advisory providers to establish robust, audit‑ready processes and reduce long‑term reliance on default values.

Using a different supply chain may also help reduce the cost implications if verified data is not available later in 2026.

Do you need further help or advice?

Article reviewed by the InterTradeIreland Trade Hub Team: April 2026