Actual vs Default CBAM Emission Values: How to Get Your Actual Data
SA exporters who provide verified actual emission data pay less CBAM than those who rely on EU default values. This guide explains the difference, the calculation methodology, and how to get your actual data verified.
Why Actual Data Beats Defaults Every Time
The single most impactful action a South African exporter can take to reduce their EU buyers' CBAM costs is to provide verified actual emission data instead of relying on EU default values.
The Two Paths
Path 1: EU Default Values — Your EU buyer uses the EU Commission's published default emission values. No action required from you — but your EU buyer pays maximum CBAM costs.
Path 2: Verified Actual Values — You calculate your actual embedded carbon, have it verified, and provide it to your EU buyer. Your EU buyer purchases fewer certificates and pays lower CBAM costs.
The Calculation Methodology
The EU CBAM calculation methodology is defined in Commission Implementing Regulation (EU) 2023/1773. Key concepts:
Specific Embedded Emissions (SEE): Total embedded carbon per tonne of product (tCO₂e/tonne).
Direct Embedded Emissions: Scope 1 emissions from your production process divided by tonnes produced.
Indirect Embedded Emissions: Scope 2 emissions from electricity consumption divided by tonnes produced.
The Verification Requirement
From 2026, actual embedded carbon data must be verified by an accredited third-party verifier. Without verification, your actual data will be treated as EU default values.
For a complete CBAM compliance registration pathway, visit the Digital Product Passport Registry.
Frequently Asked Questions
Complete all three compliance gates — Gate 1 KYC identity verification, Gate 2 CBAM financial authorisation, and Gate 3 Digital Product Passport registration — in one place at the DPP Registry.
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