CBAM Default Values by Country: Steel, Aluminium, Cement, Hydrogen (2026)

Last updated 2026-10-23·Data: Commission CBAM default-values workbooks (Implementing Regulation (EU) 2026/1740 correcting (EU) 2025/2621), workbook snapshot retrieved 2026-10-20T03:04:41Z

Short answer: CBAM default values are set per product code and per country of origin, and the gaps are enormous. One silicon-steel line (CN 7225 11 00) spans 13.24 down to 2.83 tCO2e per tonne across its 33 listed origins—a 4.7× spread—and unwrought aluminium stretches 8.9× from cheapest to priciest origin. On top sit sector mark-ups of 10% (2026), 20% (2027) and 30% (2028 onward). Sourcing geography, not just quantity, decides your certificate bill.

Importers preparing 2026 CBAM declarations already know the regime's core promise: if you cannot verify the embedded emissions of your product, the Commission supplies a conservative fallback figure. What far fewer declarants realize is how much that fallback varies by where the goods were produced. Two importers bringing in the same CN eight-digit product, in the same quantity, pay certificate bills separated by factors of two to nine purely because the origin column of the default-value tables differs. This guide quantifies that spread with the Commission's own corrected workbook data—the same dataset behind our searchable CBAM default-value tables—and walks through the arithmetic the tables imply.

What CBAM default values are, legally

Article 7 of Regulation (EU) 2023/956 obliges declarants to report the embedded emissions of each covered import. Where neither installation-level data nor a recognised equivalent exists, Article 7(7) empowers the Commission to publish default values; the operative set was laid down by Implementing Regulation (EU) 2026/1740 correcting (EU) 2025/2621 and entered into force on 1 January 2026. They exist for goods in the iron and steel, aluminium, cement, fertilisers and hydrogen sectors, expressed in tonnes of CO2-equivalent per tonne of product, with separate columns for direct, indirect and total emissions. Because defaults must err high rather than low, a mark-up is phased in over three years—conservatism by design, not a bug.

The mark-up schedule: 10%, 20%, 30%

The original implementing regulation printed ready-computed mark-up columns for 2026, 2027 and 2028. The July 2026 corrigendum, IR (EU) 2026/1740, deleted those columns to remove rounding inconsistencies, leaving the base default values and the sector percentages as the operative inputs. Apply the percentage to the base value yourself:

Sector	2026 mark-up	2027 mark-up	2028 onwards
Iron and steel	10%	20%	30%
Aluminium	10%	20%	30%
Cement	10%	20%	30%
Hydrogen	10%	20%	30%
Fertilisers	1%	1%	1%

Fertilisers are the outlier on purpose: the co-legislators judged that a punitive mark-up would hit food-chain costs hardest, so their defaults carry only a 1 percent premium in every year. For everything else, plan on paying a third more than the printed base value by 2028—before a single certificate price movement is counted.

Same code, different country: the spreads that matter

All tables below are recomputed from the Commission workbooks at generation time; nothing is hand-copied. Direct-emission defaults are shown; totals match wherever the indirect component is nil for the line.

Direct-emission default values, tCO2e per tonne, CN 7225 11 00 (silicon-electrical flat-rolled steel); the five highest and the lowest of 33 listed origins
Country of origin	Default value (tCO2e/t)
Indonesia	13.24
India	8.58
Türkiye	8.50
China	8.09
Other Countries and Territories	7.10
Taiwan	2.83

Indonesia's 13.24 reflects a grid- and process-intensive average; Taiwan's 2.83 sits near the efficient frontier for this route. India (8.58) and Tuerkiye (8.50) bracket the middle of the ranking alongside China (8.09).

Aluminium: the widest spread of all

The chapter-level unwrought aluminium row (CN 7601) shows the starkest gap in the entire dataset:

Unwrought aluminium, chapter-level default values (CN 7601): the three highest and the lowest of 68 listed origins
Country of origin	Default value (tCO2e/t)
Mozambique	3.20
China	3.00
South Africa	2.36
Zimbabwe	0.36

Mozambique tops the extraction at 3.20 tCO2e per tonne while hydro-powered producers such as Zimbabwe enter at just 0.36—a 8.9× multiple. For high-volume metal traders the origin mix is the single biggest CBAM lever after actual-data verification.

Hydrogen and cement in comparison

Distinct hydrogen default values grouped by value, CN 2804 10 00
Country grouping	Default value (tCO2e/t)
China, United States	26.64
South Africa	25.94
Other Countries and Territories	17.74
Albania, Belarus, India +7 others	14.03
Kuwait, Saudi Arabia	13.45
Algeria, Angola, Argentina +76 others	10.82

China and the United States share the steepest hydrogen default at 26.64 tCO2e per tonne, 1.9× India's 14.03. Grey Portland cement (CN 2523 29 00) ranges from 1.39 (India) down to 0.83 (Taiwan), a 1.7× band that flows straight into clinker and downstream cement articles.

Worked example: one container line, two origins

Take 100 tonnes of CN 7225 11 00 declared in 2026. Applying the 10 percent mark-up to the base default and valuing certificates at an illustrative EUR 70 per tonne of CO2e:

Origin	Base default	+10% (2026)	Certificates (100 t)	Bill @ EUR 70
Taiwan	2.83	3.113	311.3 tCO2e	EUR 21,791
Indonesia	13.24	14.564	1,456.4 tCO2e	EUR 101,948

The EUR 80,157 difference is not duty, freight or margin variation—it is the price of the origin column alone, and it recurs with every shipment. Replace the illustrative price with the weekly ETS auction average under Article 21 and the arithmetic structure stays identical.

Escaping defaults with actual data

Defaults are a floor, not a verdict. Declarants who obtain verifiable installation-specific emissions from their supplier—audited under the Commission's methodologies—can substitute actuals and typically cut the certificate bill materially, especially against high-default origins. The economics are asymmetric: verification costs a few thousand euros per supplier; the spread documented above is measured in tens of thousands per hundred tonnes at current price levels. Screen your supplier portfolio by default-value exposure first—our iron and steel dataset pages let you look the exposure up per CN code.

Frequently asked questions

What are CBAM default values and when must I use them?

Default values are Commission-published emission intensities, per product code and country of origin, that CBAM declarants must use whenever they cannot obtain verified installation-specific data from their supplier, under Article 7 of Regulation (EU) 2023/956. They are deliberately conservative: a mark-up is added on top so that unverifiable supply chains never under-report embedded emissions. The base figures behind this guide come from the corrected Annex I workbooks (Implementing Regulation (EU) 2026/1740 correcting (EU) 2025/2621), workbook snapshot retrieved 2026-10-20T03:04:41Z.

How large is the CBAM mark-up in 2026, 2027 and 2028?

For iron and steel, aluminium, cement and hydrogen the mark-up is 10 percent in 2026, rising to 20 percent in 2027 and 30 percent from 2028 onward; fertilisers stay at 1 percent throughout. Multiply the applicable base default value by 1.10, 1.20 or 1.30 depending on the year of import. Note that the corrigendum IR (EU) 2026/1740 removed the pre-computed mark-up columns from the published tables, so declarants apply the percentage themselves to the base value.

Which country has the highest CBAM default value for steel?

For silicon-electrical flat-rolled products (CN 7225 11 00) our extraction ranks Indonesia highest among the 33 listed origins at 13.24 tCO2e per tonne, ahead of India and Tuerkiye, while the lowest listed origin sits at 2.83 tCO2e per tonne--a 4.7x spread within one product code. Country choice alone can therefore swing the CBAM line item by several times before any duty or freight is considered.

Do default values differ between China and India for the same code?

Yes, sometimes dramatically. For hydrogen (CN 2804 10 00) the default for China is 26.64 tCO2e per tonne against 14.03 for India--roughly 1.9x higher for the identical CN code--because the figures reflect each country's average production mix. The same pattern holds across steel and cement: the country column of the Annex I tables is a first-class input, not a footnote.

How do I convert embedded emissions into a euro certificate bill?

Certificates are surrendered annually at a price tracking the weekly EU ETS allowance auction average under Article 21 of Regulation (EU) 2023/956. Multiply marked-up embedded tonnes by the certificate price for your estimate. In our worked example, 100 tonnes of CN 7225 11 00 from Taiwan costs about EUR 21,791 versus EUR 101,948 from Indonesia at an illustrative EUR 70 per certificate--a EUR 80,157 gap driven purely by sourcing geography.

Sources and methodology

Default values: Annex I (per-country tables) and Annex IV (highest defaults) of Implementing Regulation (EU) 2026/1740 correcting (EU) 2025/2621; benchmark values: Implementing Regulation (EU) 2025/2620. Structured extraction: data/cbam_defaults.json, 12,540 country-level default rows across 122 origins, 283 Annex IV rows and 570 CN8 benchmark products (workbook snapshot retrieved 2026-10-20T03:04:41Z); licensed for redistribution as EU legislative text under Decision 2011/833/EU with attribution to the European Commission. Every computed figure on this page is regenerated from that artifact at build time; nothing is hand-copied. Certificate-price scenarios are illustrative; the surrender price follows Article 21 of Regulation (EU) 2023/956.

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