Actual values or default values: a decision, not a default
The most consequential CBAM decision a non-EU operator makes is whether its declaration rests on actual monitored data or on default values. It is frequently made by omission — the data was not collected during the year, so defaults are the only remaining option. This note sets out what the rules permit and what each path requires.
Defaults apply where actual values cannot be determined.
Implementing Regulation (EU) 2025/2547 sets out the methods for calculating emissions embedded in goods, covering direct emissions, indirect emissions from electricity consumption, and the embedded emissions of precursor materials. Its Article 11 restricts the use of default values to situations where actual values cannot be determined; Article 12 permits alternative default values only where specific conditions are satisfied and after formal adoption. Source: EUR-Lex — Implementing Regulation (EU) 2025/2547, checked 01 September 2026.
The regulation also allows the two to be combined: Article 15 permits actual emissions to be calculated for a complex good while default values are used for one or more of its precursors. That is a legitimate, documented mixture — not a licence to fall back wherever the data is inconvenient.
What each one actually costs.
Actual values
Monitored, documented, verified- Requires a monitoring plan in place before the reporting year, containing at least the Annex II elements.
- Requires production processes and system boundaries defined per good and per CN code.
- Requires precursor data obtained from suppliers, with its own traceability.
- For electricity, requires the Annex IV conditions of Regulation (EU) 2023/956 to be demonstrated with evidence.
- Reflects your real performance — which for an efficient producer is the point.
Default values
The fallback where actual data is unavailable- No monitoring investment in the reporting year.
- Available only where actual values cannot be determined.
- Does not reflect installation-specific efficiency, fuel mix or abatement.
- The resulting certificate cost falls on the importer — and reappears in the commercial negotiation.
- Offers nothing to a producer whose real intensity is below the default.
How to make the choice deliberately.
Estimate your actual intensity first
A rough internal calculation, even at low precision, tells you which side of the default you sit on. This costs days, not months, and it determines everything that follows.
Week 1Quantify the gap in certificate terms
Multiply the difference between your intensity and the applicable default by the tonnage exported to the EU. That figure is the annual value of the monitoring investment — and it is usually the number that settles the internal argument.
The business caseWrite the monitoring plan before the year starts
Actual values are unavailable retrospectively. A plan adopted mid-year covers only the part of the year that follows it, and the verifier will say so.
Before 1 JanuarySecure precursor data contractually
Your suppliers hold data you need and have no obligation to give it to you. That obligation is created in the purchase contract, not in a request email during the verification.
Supply chainDecide the mixture explicitly
Actual for the good, defaults for named precursors, is permitted under Article 15 — but it must be documented as a decision with its reason, not discovered by the verifier as a gap.
Documentation
What we can and cannot do here.
Energy Up International is a validation and verification body. We can examine a monitoring plan, an emissions calculation and an evidence file, and we can tell you whether they are verifiable. We cannot design your monitoring, calculate your emissions, or select your values — doing so would disqualify us from verifying the result.
Preparation work of that kind is available from advisory firms, including Extreme Energy Solutions within this group, which operates as a separate entity. Where a client uses that route, the verification is performed by a different body with no involvement in the preparation, or by an independent function with no conflict of interest.
Accredited CBAM verification is not yet something we offer. Our application has been formally accepted by ACCREDIA under case C DC 07/2026 and the assessment is underway. Until it is granted, we say so on every page where CBAM appears.
Primary sources
- Commission Implementing Regulation (EU) 2025/2547 — methods for calculating emissions embedded in goods — eur-lex.europa.eu/eli/reg_impl/2025/2547/oj/eng (checked 01 September 2026)
- Regulation (EU) 2023/956 — CBAM framework, including Annex IV conditions for electricity — eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R0956 (checked 01 September 2026)
- Commission Implementing Regulation (EU) 2025/2546 — CBAM verification principles — eur-lex.europa.eu/eli/reg_impl/2025/2546/oj/eng (checked 01 September 2026)
- European Commission — CBAM definitive regime — taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en (checked 01 September 2026)
- European Commission — guidance documents published 14 August 2026 — taxation-customs.ec.europa.eu/news/european-commission-publishes-series-guidance-documents-support-cbam-implementation-definitive-2026-08-14_en (checked 01 September 2026)
Editorial note. Author and technical review above are editorial functions. They are separate from the independent technical review and the decision functions required under ISO/IEC 17029:2019, which apply to validation and verification engagements and not to published articles. Nothing on this page is advice on a specific engagement, and nothing here extends or replaces the accreditation records.
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