CBAM default values versus actual emissions: what each means

Two official emissions-data routes

Regulation (EU) 2023/956 defines actual emissions as emissions calculated from primary production-process data. It defines a default value as a value calculated or drawn from secondary data that represents the embedded emissions in goods.

Those are different data bases, not two labels for the same number. A preparation record should identify whether a figure is an official default or an installation-specific actual value, together with its period, unit, source, and supporting reference.

Goods other than electricity

Current Article 7(2) provides two routes for goods other than electricity: embedded emissions may be determined from actual emissions under points 2 and 3 of Annex IV, or by reference to default values under point 4.1 of Annex IV.

Commission Implementing Regulation (EU) 2025/2621 establishes the definitive default values and uses a conservative mark-up framework for non-electricity goods. The detailed calculation rules for actual emissions sit in Commission Implementing Regulation (EU) 2025/2547.

Electricity follows a different starting rule

For imported electricity, current Article 7(3) starts from the official default value. Actual emissions may be used only where the authorised CBAM declarant demonstrates that the criteria in point 5 of Annex IV are met.

That difference matters when reading a generic statement about actuals and defaults. The relevant route depends on the type of good and the current official rules; it should not be inferred from whether a supplier figure looks lower or more favourable.

Actual emissions bring verification requirements

Where the declaration is based on actual emissions, Article 8 requires the declared emissions to be verified by a verifier accredited under Article 18. The operator's emissions report, monitoring and calculation information, and supporting records are therefore part of the actual-emissions route.

Under Article 15 of Commission Implementing Regulation (EU) 2025/2547, an actual-emissions calculation for a complex good can use actual emissions for its production processes while permitted default values are used for one or more precursors. Where the declaration is based on actual emissions, Article 8 verification covers the total actual embedded emissions declared.

A supplier-reported number is useful preparation input, but it is not automatically a verified actual value. Keep the supplier, installation, goods, production process, reporting period, method, report version, and evidence reference attached to the figure so the appropriate reviewer can assess it.

The regulation is binding; the workbook helps navigation

The European Commission's legislation-and-guidance page states that the legally binding values are set out in Commission Implementing Regulation (EU) 2025/2621. The downloadable Excel workbook is provided for information purposes only.

Use the workbook to locate the country, product description, production route, source row, and period, then verify the legally binding source. An unavailable workbook cell is not zero and should not be replaced with a nearby product, another route, or an unsupported average.

What a comparison can and cannot show

Where an exact official default row and a supplier-reported total intensity are available on a comparable basis, a side-by-side comparison can show the numerical difference. That can help procurement and finance see why the data source matters.

The CBAM Pulse comparison does not decide customs origin, product classification, which source row applies, whether the supplier calculation meets the official method, or whether a declaration may use the actual value. It is a preparation comparison, not an applicability or verification decision.

A practical sequence

Confirm the CN code and goods type first. Identify the exact official default source row and period. Record any supplier actual value with its method and evidence. Keep unavailable information visible, arrange verification where actual emissions are used, and route unresolved applicability questions to the national competent authority or a qualified adviser.