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What are CBAM Default Emission Values — and Why They Cost More

CBAM default emission values are the EU's fallback emission factors applied when an SA exporter cannot provide verified actual data. They are set higher than SA actuals — meaning EU buyers pay more certificates than necessary.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

Default Emission Values: The Penalty for Not Measuring

CBAM default emission values are the EU's fallback mechanism for situations where an SA exporter cannot or does not provide verified actual embedded carbon data.

What Default Values Are

Default emission values are published in Commission Implementing Regulation (EU) 2023/1773. They are set using the 'worst-performing EU producer' methodology — intentionally high to incentivise exporters to provide actual data.

The Cost Difference: Defaults vs Actuals

The gap between default values and SA actuals varies by sector but is consistently significant. For SA aluminium, the difference between actual data and EU default can mean 40–60% more certificates for EU buyers. For a 10,000-tonne shipment, this can represent millions of euros in unnecessary certificate costs.

How to Avoid Default Values

  1. ▸Measure your embedded carbon using Commission Implementing Regulation (EU) 2023/1773
  2. ▸Get third-party verification from an accredited verifier
  3. ▸Provide data in the correct format via the Digital Product Passport Registry

For a complete CBAM compliance registration pathway, visit the Digital Product Passport Registry.

Frequently Asked Questions

What are CBAM default emission values?
CBAM default emission values are the EU Commission's fallback embedded carbon figures applied when an SA exporter cannot provide verified actual embedded carbon data. They are published in the EU CBAM Implementing Regulation and are set based on the average emission intensity of EU production for each sector — typically using the worst-performing EU producers as the reference point.
Why are default values higher than SA actuals?
Default values are set using the 'worst-performing EU producer' methodology. SA producers, despite using coal-heavy electricity, often have lower process emissions than the EU worst-case default. Providing actual data almost always results in a lower CBAM liability than using defaults.
What happens if my EU buyer uses default values for my products?
Your EU buyer will purchase more CBAM certificates than necessary — paying more than the actual carbon cost of your goods. This creates a commercial disadvantage: your EU buyer faces higher costs and may seek to recover these through lower purchase prices or by switching suppliers.
How do I provide actual emission data instead of defaults?
You must: (1) calculate your embedded carbon using the methodology in Commission Implementing Regulation (EU) 2023/1773; (2) have your calculation verified by an accredited third-party verifier; and (3) provide the verified data to your EU buyer in the format required by the EU CBAM Registry.
Are default values the same for all countries?
No. The EU CBAM Implementing Regulation sets different default values for different countries and regions based on their average emission intensity. Countries with higher average emission intensities have higher default values. South Africa's default values reflect its coal-heavy electricity grid.
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