CBAM default values or actual installation data?

Embedded emissions in a CBAM declaration can come from two places: the installation’s actual measured data, or the default values published by the Commission. The second route is operationally almost free — no measurement, no verification, no supplier correspondence. The price of that convenience shows up in the certificate count.

How defaults are set

Defaults are not derived from the average of production in exporting countries but from its poorly performing segment. The logic is incentive-based: if the default reflected the average, no better-than-average producer would have an economic reason to measure. Derived from the weak segment, an efficient producer gains by measuring.

The practical consequence: if your installation performs better than the sector average, using defaults is a direct loss. The embedded emissions gap between a modern EAF steel plant and an old BF-BOF plant can be more than twofold; a default value makes that gap invisible and penalises the efficient producer.

When defaults may be used

• When installation data simply cannot be obtained — typically spot purchases or trading intermediaries
• When a precursor supplier refuses to share data, for that precursor line only
• For minor inputs whose contribution to total embedded emissions is negligible
• During the transitional period, as a stopgap so reporting is not interrupted

Any use beyond that list is a commercial choice — and usually the wrong one. In the definitive period a default-based declaration raises the certificate cost directly, so your importer will bring it into the price negotiation.

The cost of moving to actual data

Moving to actual data creates three cost lines: measurement infrastructure (meters, weighing, lab analysis), data management (collection, calculation, documentation) and verification (accredited verifier fees). For a mid-sized installation the first-year total typically lands in the five-figure euro range; in later years only verification and maintenance remain.

The payback calculation is simple: annual EU export volume × (default embedded emissions − actual embedded emissions) × certificate price. With carbon in the 70–90 euro per tonne range, a producer exporting 20,000 tonnes a year with a 0.3 t CO₂e per tonne advantage is looking at more than 400,000 euros a year. The measurement investment pays for itself in the first quarter.

Data quality decides verification

Declaring actual data means being able to defend it. The verifier will ask about measurement points, calibration records, how data gaps were filled and whether the calculation steps are traceable. This is the same discipline as data quality rating on the LCA side; the difference is that in CBAM the result is a tax base.