CBAM Default Values: What the Revisions to Annexes I and IV Mean for Your CBAM Declaration

The European Commission has amended the annexes to the CBAM default values. Implementing Regulation (EU) 2026/1740 of July 20, 2026, amends Annexes I and IV to Implementing Regulation (EU) 2025/2621 and was published in the Official Journal on July 31, 2026. For importers, this means that the figures they use to calculate their gray emissions for the 2026 import year have changed—but the calculation rules have not. Here’s what needs to be reviewed now, and when it makes sense to go to the trouble of determining actual values.

Key Points at a Glance

• Annexes I and IV to Implementing Regulation (EU) 2025/2621 were amended by Implementing Regulation (EU) 2026/1740 of July 20, 2026, published in the Official Journal on July 31, 2026.
• Errors in table values and product codes were corrected, but not the calculation methods.
• The annexes to the regulation are legally binding, not the Excel file on the Commission’s website. That file is still dated February 13, 2026, and is expressly intended for informational purposes only.
• The surcharge will remain tiered: 10% (2026), 20% (2027), 30% (beginning in 2028) of the country-specific standard value; for fertilizers, 1%.
• A substantive revision of the default values is still pending —according to the implementing act, by December 2027 at the latest.
• The first CBAM declaration for the calendar year 2026 must be submitted by September 30, 2027.

As of August 2026

What changes has the European Commission made to the CBAM standard values?

With Implementing Regulation (EU) 2026/1740 of July 20, 2026, the Commission corrected Annexes I and IV to Implementing Regulation (EU) 2025/2621. The corrections addressed erroneous values in the tables and incorrect commodity codes. The methods for calculating gray emissions remain unchanged. The Commission lists the legal act on its overview page as a “correcting act” to the standard values.

The practical issue lies in the timing. The original default values were published on December 31, 2025—one day before the start of the CBAM regulatory phase. Seven months passed before the correction was made; the trade press strongly criticized the delay and pointed out that the Commission had corrected only technical errors, not the substantive discrepancies between input materials and downstream products. According to an analysis by cbamguide.com, the corrected version applies retroactively as of January 1, 2026, and thus covers the entire 2026 import year—this interpretation is based on a secondary source and should be verified against the text of the regulation on a case-by-case basis.

What are CBAM default values—and when do you need to use them?

CBAM default values are emission intensities established by the Commission for each commodity code and country of origin. They are used in place of actual facility data when such data is not available. They become mandatory in two cases: when the manufacturer does not monitor and calculate the gray emissions using the prescribed methods, or when the calculated values have not been verified by an accredited testing body.

Definition: Default values in the CBAM —country-specific emission intensities for gray emissions, established in Implementing Regulation (EU) 2025/2621 (corrected by (EU) 2026/1740) and made available in the CBAM registry. They are calculated using the same methodology as actual values, but at the country level rather than the facility level, and include a mark-up. The legal basis for their use is Article 7 of the CBAM Regulation (EU) 2023/956.

For electricity, the logic is reversed: Standard values are the norm, and actual values are permitted only under strict conditions. Anyone who wants to build the framework for gray emissions from the ground up will find the fundamentals in our approach to corporate carbon footprinting (CCF).

How much is the surcharge on CBAM benchmark values?

A surcharge is added to the country-specific standard value, which increases over three years: 10% in 2026, 20% in 2027, and 30% starting in 2028. For fertilizers, the surcharge is 1%. The Commission justifies this special treatment on the grounds of food security and the sector’s price sensitivity. The surcharge is not a fine, but rather an incentive for measurement and verification.

Year: Iron and Steel, Cement, Aluminum, Hydrogen, Fertilizers; Legal Basis: 2026: +10% of the country-specific standard value + 1% IR (EU) 2025/2621; 2027: +20% + 1% IR (EU) 2025/2621, starting in 2028: +30% +1% IR (EU) 2025/2621

Source: European Commission, Questions and Answers on the CBAM, December 17, 2025.

How the surcharge translates into euros depends on the allowance price. For the first quarter of 2026, the Commission has published a price of 75.36 euros per metric ton of CO₂; for the second quarter, 75.28 euros; and the price for the third quarter of 2026 will be published on October 5, 2026. Quarterly prices will apply in 2026, and weekly prices will apply starting in 2027. We’ve covered the details on pricing and the start of sales in our article on CBAM allowances.

Which data source takes precedence—the regulation or the Excel spreadsheet?

Only the annexes to Implementing Regulation (EU) 2025/2621, as corrected by (EU) 2026/1740, are legally binding. The Excel file containing the default values on the Commission’s website is expressly intended for informational purposes only and is still current as of February 13, 2026. Anyone who has based their calculations on this file is currently working with the uncorrected figures.

In practice, this leads to a specific verification step: Compare each combination of commodity code and country of origin used in your calculation against the corrected annexes, and document which version you used and when. This documentation will later be the difference between a justifiable figure and one that is open to challenge. The default values are also provided in the CBAM registry.

When is it worth switching from standard values to actual values?

The switch is worthwhile as soon as the verified facility emissions fall significantly below the country-specific default value and the quantity introduced covers the verification costs. As the premium increases, the calculation shifts year after year in favor of actual values. A prerequisite is always the participation of the facility in the third country—without a monitoring plan and audit report, the default value remains in effect.

CriterionStandard ValuesActual ValuesData SetCountry- and Product-Specific AverageEmissions from the Specific Production FacilityMarkup10 / 20 / 30 % per year (fertilizer 1 %)No markupManufacturer RequirementNoneMonitoring and calculation in accordance with IR (EU) 2025/2547 Verification Not required Accredited testing laboratory in accordance with IR (EU) 2025/2546 and DR (EU) 2025/2551 Evidence in the declaration Specification of the default value Copy of the test report (Art. 8, Annex VI of the CBAM Regulation) Effort Minimal Supplier process, on-site inspection, documentation

Sources: DEHSt regarding the use of standard values or actual values; IR (EU) 2025/2547; IR (EU) 2025/2546; DR (EU) 2025/2551.

What are the relevant deadlines for the CBAM declaration?

The first CBAM declaration must be submitted by September 30, 2027, for the calendar year 2026; in subsequent years, the deadline is September 30 for the preceding calendar year. The declaration must include gray emissions by product type as well as a copy of the audit report, provided that actual values are used. Permits will be sold via the central platform starting in February 2027.

Also relevant: The de minimis rule exempts imports of CBAM goods with a total weight of less than 50 metric tons per year from CBAM obligations. This threshold does not apply to electricity and hydrogen—for those, the obligations take effect starting with the first import. The window for data collection from 2026 production thus extends into the first half of 2027.

Our Assessment

The correction is, in and of itself, a mere formality—but its impact is not. Anyone who relied on standard values in 2026 will have to redo their calculations without receiving a reliable, updated working file from the Commission. Based on our project work, we’ve identified two patterns: Companies that have documented their commodity code assignments clearly and with version control need only a few hours to perform the reconciliation. Companies working with a complex, ad-hoc Excel environment need weeks—and often uncover other issues in the process.

In terms of content, the more important issue remains unresolved. The Commission has corrected only technical errors; according to the implementing act, a substantive revision of the standard values and markups is pending until December 2027 at the latest. Anyone who calibrates their procurement strategy based on today’s default values is planning on the basis of figures that may change again. Only a verified asset value is reliable. That is why we consider the supplier integration—monitoring plan, auditability, and contractual data requirements—to be the actual investment, not the annual revaluation of the default values. For importers whose exposure to the CBAM will expand further in 2028, time pressure comes from two sides; we have addressed this in our analysis of the CBAM’s expansion to downstream products. Those who also ship to or source from the United Kingdom should simultaneously consider the differences from the UK CBAM.

Conclusion

Correcting Annexes I and IV does not require a new process, but it does require a documented reconciliation: What standard values did your company use for 2026, from which version, and what changes as a result of the corrected annexes? Those who perform this reconciliation now will have until the reporting deadline on September 30, 2027. The strategic question is a different one: At what volume and with what markup does the verified asset value become cost-effective—and which suppliers are even capable of supporting this?

We work with importers to establish precisely this basis for decision-making: an impact analysis by commodity code and country of origin, a comparison of the standard value against the achievable facility value, supplier integration, and verifiable documentation. If you’d like to know where your portfolio stands, please contact us regarding CBAM reporting and CBAM compliance.

Sources

1. European Commission (DG TAXUD): CBAM legislation and guidance (accessed in August 2026) — https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en
2. EUR-Lex: Commission Implementing Regulation (EU) 2026/1740 of July 20, 2026, correcting Implementing Regulation (EU) 2025/2621 with regard to Annexes I and IV (Official Journal of July 31, 2026) — https://eur-lex.europa.eu/eli/reg_impl/2026/1740/oj
3. EUR-Lex: Commission Implementing Regulation (EU) 2025/2621 establishing standard values (published on December 31, 2025) — https://eur-lex.europa.eu/eli/reg_impl/2025/2621/oj
4. European Commission: Questions and Answers on the Carbon Border Adjustment Mechanism (CBAM), QANDA/25/3089 (December 17, 2025) — https://europa.eu/newsroom/ecpc-failover/pdf/qanda-25-3089_de.pdf
5. German Emissions Trading Authority (DEHSt): Use of default values or actual calculated emissions (accessed in August 2026) — https://www.dehst.de/DE/Themen/CBAM/CBAM-regelphase-ab-2026/_docs/akk-erklaerung-standardwerte_artikel.html
6. German Emissions Trading Authority (DEHSt): CBAM Regular Phase Starting January 1, 2026 (as of March 12, 2026) — https://www.dehst.de/DE/Themen/CBAM/CBAM-regelphase-ab-2026/cbam-regelphase-ab-2026_artikel.html
7. European Commission: Price of CBAM certificates (accessed in August 2026) — https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en
8. EUR-Lex: Commission Implementing Regulation (EU) 2025/2547 on methods for calculating gray emissions (accessed in August 2026) — https://eur-lex.europa.eu/eli/reg_impl/2025/2547/oj
9. EUR-Lex: Commission Implementing Regulation (EU) 2025/2546 on the application of audit standards (accessed in August 2026) — https://eur-lex.europa.eu/eli/reg_impl/2025/2546/oj
10. EUR-Lex: Commission Delegated Regulation (EU) 2025/2551 on Accreditation and Verification (accessed in August 2026) — https://eur-lex.europa.eu/eli/reg_del/2025/2551/oj
11. Steel News by Gerber Group: CBAM Default Values – 7 Months for a Technical Correction (August 4, 2026) — https://steelnews.biz/cbam-default-values-7-months-technical-correction/
12. cbamguide.com: CBAM Default Values 2026 – Country List, Markups, and How to Avoid Them (accessed in August 2026) — https://cbamguide.com/compliance/default-values/

About the Author

At Five Glaciers Consulting, Dr. Merlin C. Köhnke assists industrial and commercial companies with CBAM impact analyses, emissions calculations, and the preparation of auditable documentation of regulatory metrics. He is available to answer questions about this article at merlin.koehnke@fiveglaciers.com.