On December 17, 2025, the European Commission released 24 key regulatory documents detailing the implementation of the formal taxation period for the Carbon Border Adjustment Mechanism (CBAM). These documents provide clear answers to core issues: establishing official default values for various products covered by CBAM.
This default value mechanism is global in scope, currently incorporating relevant data from 122 countries and regions worldwide, with data missing for some countries and regions.
The regulations specify the different scenarios in which default values apply. For companies, when verified actual emission data cannot be provided, importers may opt to use default values for declaration. However, correctly selecting and applying default values based on the specific circumstances of the product and the state of the supply chain involves professional judgment and accurate application of complex rules.
I. What are the Default Values Set by the EU?
The Default Values in CBAM are unified emission intensity coefficients directly set by EU authorities when companies choose not to provide their own actual emission data. They directly determine the upper limit of the carbon cost companies must pay and are a key basis for companies to assess compliance risks and costs. The released default values are not only higher than the transitional period data but, except for electricity products, will also gradually increase by 10% from the 2025 baseline starting in 2026, and by 30% after 2028.
The following is a summary of key points regarding default values:
Therefore, from the mechanism design, it is evident that default values are essentially options with clear economic punitive attributes (such as the 10% markup rule). As importers directly bearing the obligation of carbon tariffs, they are certainly unwilling to pay taxes using high default values.
II. How are Default Values Used in Different Situations?
For situations where actual values cannot be used for calculation, the EU has defined five specific scenarios for the application of default values. Each scenario corresponds to different data-missing situations, and their usage rules vary:
- If a country or region is explicitly listed and a value is provided, use the default value for the corresponding product from the country listed in Appendix I.
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(2) If a country or region is not explicitly listed, and no value is provided or the relevant field shows "--", use the default value for the corresponding goods from the "Other Countries and Regions" table in Appendix 1.
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(3) For indirect emissions, if the goods are listed in Appendix 1 of Regulation (EU) 2023/956 but not in Appendix 2 of that Regulation, use the default values from Appendix 2.
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(4) For electricity imported from the EU customs territory, use the data in Appendix 3 to select the default value for calculation.
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(5) When the origin of a precursor cannot be determined, and default values are needed to determine the specific embedded emissions of the final product or precursor, the default value from the third country with the highest emission intensity for that precursor should be used, i.e., the data from Appendix 4 of the default values.
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III. Key Takeaways and Action Recommendations
Consult Official Data: All default values (including those by product, country, and process) must be based on the latest version of the European Commission's official document "Setting of Default Values". Those in need can contact our staff via the backend to obtain it.
Universality of the "Punitive Markup": For all the above scenarios, as long as any part of the calculation uses default values, a 10% markup must ultimately be added to the total emissions. This is a key mechanism to incentivize companies to provide complete actual data.
Strategic Choice: Companies should compare these scenarios and assess their own data gaps. Generally, the larger the gap and the higher the proportion of default values used, the higher the total cost. Therefore, prioritizing the completion of data for indirect emissions and key precursor materials is a practical starting point for cost reduction.