When reporting emissions under CBAM, exporters face a choice with real financial consequences: use the EU’s default values, or use your own actual, measured data. It sounds like a technical detail, but it can noticeably change the cost attached to your goods – and therefore your competitiveness. This guide explains both options, why actual data usually wins, and what it takes to use it.
What are default values?
Default values are standard emission estimates the EU provides for each type of covered product. They exist as a fallback for situations where real, measured data is not available. The single most important thing to understand about them is that they are deliberately set on the high side. The EU designs them this way on purpose, so that no producer can gain an advantage by simply refusing to measure their emissions and hiding behind a comfortable estimate.
In effect, defaults say: “If you will not show us your real numbers, we will assume a high one.” For a genuinely high-emission producer, the default might be close to reality. For an efficient one, it usually overstates their footprint – and overstates the cost.
What are actual values?
Actual values are your real emissions, measured at your own plant and calculated from your genuine fuel and electricity use and your true production output. They tell the honest story of how carbon-intensive your specific production is. For a reasonably efficient producer, actual emissions are frequently lower than the EU’s default estimate – sometimes substantially so.
Why actual data usually wins
Because the CBAM cost is tied directly to emissions, a lower emissions figure means a lower cost for your EU buyer. If your verified actual emissions come in below the default, using them reduces the number of certificates the importer must buy – which makes your product cheaper for them than a competitor’s identical goods still priced on high default values.
Consider a quick comparison. Suppose the default value for a steel product is 2.5 tonnes of carbon per tonne of steel, but your verified actual figure is 1.8. On a 500-tonne shipment, that is the difference between 1,250 and 900 tonnes of embedded carbon – 350 tonnes less. At an effective carbon price of, say, 70 euros per tonne, that is around 24,500 euros saved on a single shipment, simply by proving your real, lower emissions. Measuring your emissions is not paperwork; it is a chance to turn genuine efficiency into a hard price advantage.
The catch: actual data must be verified
There is one firm condition. You cannot simply claim a lower number and expect it to be accepted. To use actual data in the definitive phase, your emissions must be independently checked by an accredited verifier. This is why solid record-keeping and a reliable measurement system matter so much – they are what make your real numbers usable rather than just asserted. Unverified data, however accurate, cannot be used to claim emissions below the default.
When defaults might be acceptable
Defaults are not always the wrong choice. For a very small exporter, or in the early days before your measurement and verification systems are ready, starting with default values can be a reasonable, low-effort way to keep trading. The key is to treat defaults as a temporary starting point, not a permanent setting. The moment your real emissions are likely lower than the default – which is the common case for efficient producers – investing in measurement and verification starts paying for itself.
How to move from defaults to actual data
- Begin measuring your fuel, electricity and production data now, even before you formally need it.
- Organise supporting records so a verifier can move through them quickly.
- Engage an accredited verifier to check your figures.
- Compare your verified actual value against the relevant default – if it is lower, switch to actual data and capture the saving.
The India angle
For Indian exporters, the actual-versus-default choice is especially significant. Because EU defaults for some regions and products can be set high to reflect worst-case assumptions, an efficient Indian producer relying on defaults may be paying for emissions far above their real output. Measuring and verifying actual data is often the single most effective way for a competitive Indian exporter to avoid being penalised by pessimistic assumptions.
Why the effort pays off over time
It helps to see measurement as an investment rather than a one-off cost. The first time you measure and verify your emissions, there is real effort involved – setting up data collection, organising records, engaging a verifier. But once that system exists, each subsequent year is far easier, because the process is already in place and only needs updating. Meanwhile, the saving from using actual data (when it is lower than the default) recurs on every single shipment, year after year. A cost incurred once, against a benefit repeated indefinitely, is usually a straightforward decision for any efficient producer.
Frequently asked questions
Are CBAM default values higher than actual emissions?
Usually, yes. Defaults are deliberately set on the high side so no one benefits from refusing to measure. Efficient producers often have actual emissions well below the default.
Can I use my actual emissions without verification?
No. In the definitive phase, actual emissions data must be independently verified by an accredited verifier before it can be used to claim a figure below the default.
Is it worth measuring actual emissions for a small exporter?
If your real emissions are likely below the default, yes – the cost saving usually justifies the effort. Very small exporters may start with defaults and move to actual data as systems mature.
The bottom line
Default values are the safe but expensive option; actual, verified data takes more effort but, for most efficient producers, lowers the CBAM cost and sharpens your competitiveness. The rule of thumb is simple: if you can measure and verify it, do so – your real numbers are usually your cheaper numbers.
