CBAM Default Values: Why Missing Supplier Data Costs You

Two importers bring in the same tonne of steel from the same country. One pays more CBAM than the other.

The difference is not the steel. One of them got real emissions data from the mill. The other did not, so a default value filled the gap, and that default was set high.

Under CBAM, the missing data is the cost.

This guide covers what CBAM default values are, why they are set high, and how getting actual data from suppliers lowers your bill.

What are CBAM default values?

Embedded emissions are the carbon released making your goods. Under the Carbon Border Adjustment Mechanism, you pay for them, so someone has to put a number on them.

The best number is actual data from the installation that made the goods, verified by an accredited third party. When you do not have that, the EU lets you use a default value instead: a Commission-published figure for that type of good.

Default values are the fallback, not the target. They exist so an importer is never stuck, defined under the method in Annex IV of Regulation (EU) 2023/956.

Why defaults are set high

Here is the part that costs money. Default values are set conservatively, meaning high.

That is deliberate. If a default were generous, no one would bother collecting real data, and the whole point of CBAM would leak away. A high default is the nudge that pushes importers to get actual figures.

So a default is a safe answer, not a cheap one. It almost always overstates the carbon, and you pay for every overstated tonne.

How actual data lowers the bill

Verified installation data takes precedence over defaults. If you can show the real embedded emissions, backed by an accredited verifier, you use those instead.

Two other rules move the number in your favour:

• Carbon price already paid. If a carbon price was paid where the goods were made, it is deducted, so the tonne is not charged twice.
• Direct and indirect emissions. For most goods you count direct emissions; for cement and fertilisers, indirect emissions count too. Knowing which applies stops you over-reporting.

The pattern is simple. Real data beats the default, and the gap between them is your money.

The real problem is the supplier

None of this is hard to understand. It is hard to collect.

The emissions figures live with the installation abroad, not in your system. A CBAM report or declaration is only as good as the data the supplier sends back, and suppliers are slow, or silent, or do not have the numbers themselves.

That is why CBAM is a data-collection problem before it is a carbon problem. Every unanswered request is a default value waiting to happen.

How Bindu handles the data gap

Bindu does not calculate emissions and does not connect to the CBAM Registry. What it fixes is the collection problem.

Bindu keeps each covered import on one record, sends the data request to the right supplier, and stores the reply and the verifier's proof against that import, with an owner and a date. When the figure arrives, it sits where your declaration needs it, so you are not forced onto a high default by a deadline. See the CBAM breakdown.

FAQ

What are CBAM default values? Default values are Commission-published fallback figures for the embedded emissions of covered goods. Importers use them when they do not have actual, verified emissions data from the installation that produced the goods.

Source: EUR-Lex: CBAM, Regulation (EU) 2023/956

Why do default values cost more? Default values are set conservatively, meaning high, on purpose. A high default removes any incentive to skip real data collection. Because it overstates the carbon, an importer relying on defaults almost always pays more than one using verified actual data.

Source: European Commission: Carbon Border Adjustment Mechanism

How are CBAM embedded emissions calculated? Per Annex IV of the CBAM regulation: direct emissions per tonne of goods, plus indirect emissions for cement and fertilisers. Any carbon price already paid in the country of production is deducted, and verified actual installation data takes precedence over default values.

Source: EUR-Lex: CBAM, Regulation (EU) 2023/956

Can I always use default values instead of collecting data? Default values are a fallback, not a free choice that saves effort. Because they are set high, they cost more, and verified actual data takes precedence when you have it. Collecting real supplier data is how you lower the bill.

Source: EUR-Lex: CBAM, Regulation (EU) 2023/956

Who provides the emissions data for CBAM? The installation that produced the goods, abroad. The importer must obtain those figures from the supplier and, in the definitive regime, have actual figures verified by an accredited third party. The collection burden sits with the importer.

Source: European Commission: Carbon Border Adjustment Mechanism