CBAM default values versus actual emissions: what each means

How to choose between default values and actual emissions for one import line

Before you ask if supplier numbers are lower or higher, ask what route they belong to. Each CBAM import line should be tagged as one of five actionable states, because the route is not just a label: it changes who owns evidence, what review is required, and what can be submitted in annual declaration preparation.

This page is written as a practical checklist for import teams. It helps you move from raw values and supplier messages to a prepared emissions-decision record with a confidence tag and a next action for unresolved fields. The corrected official default route uses the applicable Annex I total-emissions base row and the year-specific mark-up calculated in the CBAM Registry, so your decision model should start from that source chain before adding any supplier values. This guide does not decide legal applicability. It is for information purposes only.

For complex good production chains, use a side-by-side comparison to keep supplier actual emissions and default values visible across different precursors. Treat the route at each production process and precursor separately, and never collapse to one blended number for a finished import line.

Keep the scope narrow: covered goods, CBAM declaration prep, and route selection, including how goods other than electricity branch from electricity routes. Do not use this as a generic legal interpretation of every product variation.

The five states of a CBAM emissions figure

A stable process starts by assigning one of five states for every emissions number. Without this model, teams drift into using one number as a default and another as actual in different places.

State A is corrected official default route active: the record points to the applicable country or territory, good, production route where shown, and total-emissions base row in the corrected Annex I; the CBAM Registry applies the year-specific mark-up.

State B is supplier-reported actual candidate: useful for planning, but not enough to close the route by itself.

State C is an actual candidate with its evidence package assembled: the data package is complete enough to enter verification, but accredited verification has not yet been completed, so the value remains a candidate.

State D is verified actual route: completed accredited verification supports the actual-emissions route for declaration preparation.

State E is unsupported or indeterminate: no usable value on the required context, or a mismatch in basis. This must stay explicit and not be silently replaced.

Goods-by-goods route matrix before touching declaration drafts

Use this matrix per CN line, not once per team. If the matrix outcome is unclear, the line should not be in the declaration-ready bucket.

Keep the question order fixed; it catches the common mixed-state mistakes before they become handoff debt.

Corrected Annex I and Registry year mark-ups

Commission Implementing Regulation (EU) 2026/1740 replaced Annexes I and IV to Implementing Regulation (EU) 2025/2621 and applies from 1 January 2026. Use the corrected annexes rather than a pre-correction workbook or copied year column.

The correcting act deleted the marked-up 2026, 2027, and 2028 table columns. The CBAM Registry calculates the final marked-up default from the corrected Annex I total-emissions base value; the direct- and indirect-emissions columns are provided for information.

Navigate the corrected Annex I by country or territory, product and CN or TARIC code, production-route indicator where shown, and total-emissions value. Use the ‘Other countries and territories’ row only when the country or territory is not listed, or when its applicable field has no value or shows ‘–’, as specified in the corrected Annex I.

Do not treat a named country worksheet, an adjacent product, or a prior-year value as a fallback. The Commission workbook is an information aid; the correcting act and the Registry calculation govern the operative route.

For each prepared record, retain the corrected act version, exact base-row identity, source extraction date, and separate Registry output. CBAM Pulse organises that evidence but does not decide which row applies.

• Record Implementing Regulation (EU) 2026/1740 as the correction source.
• Record the exact corrected Annex I total-emissions base row.
• Keep the year-specific Registry result separate from the base row.
• Use ‘Other countries and territories’ only under the corrected fallback rule.
• Flag any copied year column, adjacent row, or unsupported country substitution as blocked.

Synthetic mixed-state example: candidate actual plus supported default

A practical example makes the routing logic reviewable. Use it as a training template and as a weekly QA prompt.

Example: a component line has three inputs. Input A has supported default values, input B has supplier candidate actual with missing verification fields, and input C is electricity with claimed actual but incomplete criteria evidence.

Correct prep result: do not collapse into one number. Keep A as default, B as candidate actual, and C in unresolved branch until route criteria are proven.

The objective is not perfect numbers quickly; it is decision integrity and traceability before submission windows begin.

Component-level reconciliation for product families

For families, map emissions state at component level. Product families with many inputs are where teams commonly create hidden compliance risk.

Track component name, state, missing-field owner, and due date. If one component is unresolved, the line is not fully ready even if the family summary looks complete.

• No silent default carryover across family components.
• Unsupported state remains visible and actionable, not normalized away.
• Handoff package must include source row, verification status, and remediation task for every component.

Verification boundary and handoff quality

Where actual emissions support declaration preparation, the verifier must be accredited under Article 18. A supplier-reported number remains a candidate until its method, period, scope, report reference, and verification context are complete.

Verified actual is a route quality gate, not a marketing label. The route changes only when evidence depth and verification context are complete.

A candidate actual without report version, method boundary, and period mapping is not enough for declaration-grade planning; it can still be used internally for planning and supplier conversations.

A reviewable handoff pack should let a reviewer answer these with one glance: what is the route, what is missing, and who is accountable to close it.

• Method and units
• Reporting period
• Supporting report references
• Verification scope and status
• Unresolved items and owner and date
• Exact route and default row rationale

Operational checklist: from import line to declaration-ready record

Use this as a weekly operating step before season close.

First classify route state, then anchor every value to exact source rows, then check year context, then evidence completeness. Finally create explicit unresolved tickets for anything still missing.

If a line ends unresolved, it should not be hidden for convenience. A visible unresolved line is a better outcome than a false ready status.

• Classify each line as corrected default, supplier candidate, evidence-assembled candidate, verified actual, or unsupported.
• Record source row id and last checked date.
• Set electricity/non-electricity branch before actual route decisions.
• Attach evidence owner and review owner before handoff.
• Move unresolved lines to remediation with deadlines.